Interpretation Response #06-0155 ([Transportation Systems Solutions] [Mr. Peter Olsen])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Transportation Systems Solutions
Individual Name: Mr. Peter Olsen
Location State: IL Country: US
View the Interpretation Document
Response text:
Sep 15, 2006
Mr. Peter Olsen Reference No. 06-0155
Transportation Systems Solutions
318 Hampshire Lane
Crystal Lake, Illinois 60014
Dear Mr. Olsen:
This is in response to your June 27, 2006 letter requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 100-180) applicable to testing criteria for
Hazard Division 5.1 Oxidizers. Your questions are paraphrased and addressed as follows:
Q1. Is a material that does not meet the definition of an “Oxidizer” as specified under § 173.127 of the HIVIR when it is transported in a solid tablet form required by the United Nations (UN) Manual for Test and Criteria to be ground to a powder form to conduct the oxidizer test?
Al. As specified in § 173.127 of the HMR, a solid material is classed as a D vision 5.1 material (Oxidizer) if, when tested in accordance with the UN Manual o: Tests and Criteria, its mean burning time is less than or equal to the burning time of a 3:7 potassium bromate/cellulose mixture. The UN Manual of Tests and Criteria specifies that tests are conducted on the substance to be evaluated mixed with dry fibrous cellulose in mixing ratios of 1:1 and 4:1, by mass, of sample to c The UN Manual of Tests and Criteria also specifies that a substance, in the form in which it will be transported, should be inspected for any particles less than 500 jam in diameter. If that powder constitutes more than 10% (mass) of the total, or if the substance is friable, then the whole of the test sample should be ground to a powder before testing to allow for a reduction in particle size during handling and transport. In addition, the UN Manual for Tests and Criteria specifies that, as the particle size has a significant effect on the result of the test performed to determine the potential for a solid substance to increase the burning rate or burning intensity of a combustible material, the particle size of the substance should be stated in the test report.
Q2. If the material that has been ground to a powder form meets the definition of an “Oxidizer,” does the UN Manual for Tests and Criteria allow for a specific percentage of the powder to be generated from the tablet form?
A2. See response above.
Q3.; Is there a grain size limit for the powder of the above material generated before the tablets would be considered an “Oxidizer” under § 173.127?
A3. See response above.
I trust this satisfies your inquiry.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
173.127