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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #11-0274R ([Department of the Army] [Ms. Sarah Gedrich])

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. Sarah Gedrich

Location State: PA Country: US

View the Interpretation Document

Response text:

November 13, 2013

Ms. Sarah Gedrich
Chief, LOGSA Packaging, Storage, and Containerization
Center (AMXLS-AT-L)
Department of the Army
11 Hap Arnold Boulevard
Tobyhanna, PA 18466-5097

Ref. No. 11-0274R

Dear Ms. Gedrich:

This responds to your October 13, 2011 letter requesting clarification of the package testing requirements for composite or combination packagings that contain compressed oxygen and other oxidizing gases in cylinders or chemical oxygen generators under the Hazardous Materials Regulations (HMR; 49 CFR Part 171-180).  In general terms, these articles are required to be placed in a rigid outer packaging that conforms to the testing provisions in Part 178, Subpart M of the HMR or the performance criteria of Airlines for America (A4A), formerly the Air Transport Association of America, Inc. (ATA), Specification No. 300 (“Spec 300”) for a Category I shipping container.  See §§ 173.168(d), 173.302(f)(3) and 173.304(f)(3).  You specifically request clarification of the testing and performance criteria and determination of successful test results.  

Your questions regarding Part 178, Subpart M testing are paraphrased and answered as follows:

Q1.  The HMR outline package preparation criteria for testing.  For example, inner receptacles for liquid material must be at least 98% filled (see § 178.602(b)).  However, there is no criterion for gases.  How would cylinders be filled to 98% with a gas?  

A1.  The physical properties of a gas would not allow for a cylinder to be filled to 98%.  The filling criteria for inner receptacles intended to contain liquid or solid material do not apply to gases.  Bear in mind that these drop tests should not be conducted with filled cylinders because of the inherent safety risks associated with a compressed gas.

Q2.   Following drop tests of composite or combination packaging, the absence of leakage of filling material from the inner receptacles signifies a successful test (see § 178.603(f)(4)).  If the drop test were to be conducted with empty cylinders, how would it be determined if the material leaked?  

A2.  The cylinder should be filled after the drop test to determine whether there is any leakage as a result of damage occurring during the drop test.    

Q3.  If damage to the outer packaging affects the flame penetration resistance, is this considered an unsuccessful test?   

A3.  Yes.  This would be considered damage likely to adversely affect safety during transport.

Q4.  Would the same criteria apply to the stacking test and the vibration standard?

A4.  Yes.  The responses to questions 1 thru 3 hold true for both the stacking test and the vibration standard.

Your questions regarding A4A Spec 300 and testing are paraphrased and answered as follows, however, we note that the guidance we present in this letter relative to A4A Spec 300 was offered from consultation with A4A and we recommend that you contact A4A for further guidance regarding this standard:

Q1.  Regarding the drop test of a Category I shipping container (that can be handled manually in transportation), are the drops conducted on each side, edge, or corner, in sequence or only on one selected side, corner, and edge?

A1.  The drop test is to be performed in sequence for the required number of drops for each side and repeated for the required number of drops for each edge and each corner.  The combination of 160 side (face) drops distributed among the six (6) sides, 80 edge drops distributed among the twelve (12) edges, and 40 corner drops distributed among the eight (8) corners must total 280 drops. Care should be taken under the test plan to address worst case scenarios (e.g., unevenly loaded boxes) when distributing the drops in each case.

Q2.  Regarding the cause for rejection, if the cylinders are considered the contents, how is it determined that the contents do not show any changes that affect their utility.

A2.  The determination of any “changes affecting the utility of the contents” would be similar to determination of successful testing under the HMR.  That is, the cylinder should be filled after the drop test to determine whether there is any leakage.

Q3.  Are the required tests to be performed in series?

A3.  No.  Each test type (e.g., drop, vibration, etc.) must be completed independent of the others.

Q4.  Should the utility of the packaging be determined after each test type (e.g., drop, vibration, etc.)?

A4.  Yes.  The contents of the packaging are to be inspected after the testing procedure for each test type is complete to determine whether they show any changes that affect their utility.

I hope this answers your inquiry.  If you need additional assistance, please contact this Office at (202) 366-8553.


Charles Betts
Standards and Rulemaking Division

173.168(d), 173.302(f)(3) and 173.304(f)(3)

Regulation Sections

Section Subject
173.168 Chemical oxygen generators
173.302 Filling of cylinders with nonliquefied (permanent) compressed gases or adsorbed gases
173.304 Filling of cylinders with liquefied compressed gases