Interpretation Response #05-0002 ([Raytheon -SAS] [Mr. Donald E. Burke])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Raytheon -SAS
Individual Name: Mr. Donald E. Burke
Location State: CA Country: US
View the Interpretation Document
Response text:
Mar 15, 2005
Mr. Donald E. Burke, Jr. Reference No. 05-0002
Packaging Engineer
Raytheon -SAS
P.O. Box 902
El Segundo, CA 90245
Dear Mr. Burke:
This responds to your letter to Mr. Frits Wybenga requesting clarification of the pressure requirements for air shipments under the. Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are based on a letter of interpretation to Haas TCM (Ref No. 04-0023) which addressed means to obtain the vapor pressure for the tests in § 173.27. Specifically, you ask if the vapor pressure of the material to be packaged must be determined at either 50 or 55° C to calculate the pressure retention capability of a packaging in accordance with § 173 .27(c)(2)(ii).
The answer is yes. When calculating the required vapor pressure capability as specified in § 173.27(c)(2)(ii), the vapor pressure of the packaged material must first be determined in order to utilize the formulas to calculate the pressure retention capability of the packaging.
As provided by § 173.27, each packaging must be capable of withstanding certain pressure requirements for transportation by air. This section does not require testing of each packaging; rather, it requires that packaging must be “capable” of meeting the pressure requirement without leakage. If past testing or transportation experience indicates that a packaging can withstand the pressure requirement without leakage, testing need not be performed. The test report or packaging certification should note the rationale behind the determination that the packaging meets the pressure requirements.
I trust this satisfies you request.
Sincerely,
Hattie L. Mitchell
Chief, Regulator Review and Reinvention
Office of Hazardous Materials Standards
173.27
Regulation Sections
| Section | Subject |
|---|---|
| 173.27 | General requirements for transportation by aircraft |