Interpretation Response #03-0170 ([Lawrence Livermore National Laboratory] [Mr. Earl Thomas])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 08/27/2003

Company Name: Lawrence Livermore National Laboratory

Individual Name: Mr. Earl Thomas

Location State: CA Country: US

View the Interpretation Document

Response text:

Aug 27, 2003

Mr. Earl Thomas                Reference No. 03-0170
Lab Pack Operations Team Leader
Lawrence Livermore National Laboratory
University of California
P. O. Box 808, L-668
Livermore, CA 94550

Dear Mr. Thomas:

This responds to your letter requesting clarification on authorized packaging for poison inhalation hazard (pIR) materials under § 173.226(c)(2) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Ql. We offer for transportation Division 6.1, PG I, Hazard Zone A materials in an inner packaging system consisting of three inner packagings; the HMR prescribe two inner packagings. We place a single one liter non-impact resistant glass receptacle in an impact ¬resistant packaging with compatible absorbent material. This in turn is placed into a leak¬tight packaging, again with compatible absorbent material, that is packed within an outer 4G fiberboard box. The completed inner packaging system meets the performance standards at the PG I level in subpart M, part 178, of the HMR. Does this packaging meet the requirements in § 173.226( c ) (2)?

AI. The answer is yes. Even though you have an additional inner receptacle, your packaging meets the provisions in § 173 .226( c )(2). The capacity of each inner receptacle may not exceed 4 L (1 gallon). Both the inner packaging system and the outer packaging must meet the performance test requirements in subpart M, part 178, of the HMR.

Q2. Under the provisions in §173.226(c)(2), may multiple inner impact-resistant glass receptacles containing Division 6.1, PG I, Hazard Zone A materials be packed into the
leak-tight intermediate packaging? .

A2. Section 173 .226( c )(2) authorizes multiple impact-resistant inner receptacles, provided the capacity of each inner receptacle does not exceed 4 L (1 gallon), and the total amount of liquid contained in the outer packaging does not exceed 16 L (4 gallons). Additionally, the inner packaging system and the outer packaging must conform to the performance test requirements in subpart M, part 178, of the HMR.

I hope this satisfies your inquiry.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

Regulation Sections