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Interpretation Response #06-0137 ([Department of the Army] [Ms. Lauren Oleksyk])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of the Army

Individual Name: Ms. Lauren Oleksyk

Location State: MA Country: US

View the Interpretation Document

Response text:

Sep 11. 2006


Ms. Lauren Oleksyk                 Reference No. 06-0137

Physical Scientist

Combat Feeding Directorate

Department of the Army

Kansas Street

Natick, MA 01760-5018

Dear Ms. Oleksyk:

This responds to your letter concerning transportation of a heater that is a component in a Unitized Group Ration " Express (UGR-E) under the Hazardous Materials Regulations (EIIMR; 49 CFR Parts 17 1-180). You ask how packages containing UGR-Es must be marked and labeled if they are determined to be subject to the HMR.

You describe the UGR-E as a self-contained, self-heating module that provides a complete meal for up to 18 personnel, with heaters and trays of food packaged together in an intermediate fiberboard box. A module has four heaters, each containing 85 grams of magnesium alloy powder, for a total of 340 grams per module. In the Type I version, the four heaters are hermetically sealed within a tri-laminate pouch and placed on top of the inner heating module case. In the Type II version, each hermetically sealed heater is placed in the bottom of the heating tray. The individual heaters are activated with a 300 mL solution of 1.5% salt in water which is dispensed from a pouch assembled within each heating tray. The outer packaging of each module is a fiberboard box with the completed package weighing approximately 42 pounds. During the 45-minute heating process, the four heaters generate approximately 11 cubic feet of hydrogen gas. Your correspondence included illustrations and assembly instructions for both types of UGR-E, as well as a Material Safety Data Sheet; you also provided a prototype of each module type sans heaters, and one Type I heater pouch containing four heaters.

Based on the information you provided, the most appropriate shipping description for the UGR-E is "Magnesium alloys, powder, 4.3, UN 1418, PG II." The HMR do not authorize any exceptions in column (8A) for this entry; therefore, the UGR-Es are fully regulated. When offered for transportation in commerce, in addition to meeting the specification packaging requirements in § 173.2 12, non-bulk packages must be marked as specified in § 172.30 1 (proper shipping name, identification number, etc.) and labeled with the DANGEROUS WHEN WET label in accordance with Subpart E of 49 CFR Part 172. For transportation by aircraft, packages prepared in accordance with the International Civil Aviation Organization"s (ICAO) Technical Instructions must also be marked with the name and address of the shipper and consignee.

You may wish to seek relief from some of the requirements detailed in the previous paragraph under the terms of a special permit by contacting the Pipeline and Hazardous Materials Safety Administration"s Office of Hazardous Materials Special Permits and Approvals (OHMEA). Special permits are granted on a case-by-case basis. Procedures for applying for a special permit are set forth in 49 CFR 107.105. The OHMEA may be reached at (202) 366-4512.

I trust this satisfies your request.



Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

171.2, 172.301, 172.101

Regulation Sections

Section Subject
171.2 General requirements
172.101 Purpose and use of hazardous materials table
172.301 General marking requirements for non-bulk packagings