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Interpretation Response #14-0156 ([URS Corporation] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

October 30, 2014

Mr. Andrew Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC 27560

Reference No. 14-0156

Dear Mr. Romach:

This is in response to your August 11, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the pressure test and absorbent material requirements when shipping a liquid as an excepted quantity under
§ 173.4a.  Your questions are paraphrased and answered as follows:

Q1.  Section 173.4a(a)(4) requires that packagings for which retention of liquid is a basic function must be capable of withstanding without leakage the pressure differential specified in § 173.27(c).  The above requirement does not specify which level of packaging must meet the pressure differential requirement.  You note that § 173.27(c)(3)(i) provides that hazardous materials may be contained in an inner packaging which itself does not meet the pressure requirement provided that the inner packaging is packed within a supplementary packaging which does meet the pressure requirement. You ask if the pressure test requirement in
§ 173.27(c) is satisfied if any one of the inner, intermediate, or outer packaging are capable of meeting the pressure requirement.

A1. The answer is yes.  If the inner packaging itself does not meet the pressure requirement, a supplementary packaging, either intermediate or outer,  must then be capable of withstanding the pressure requirements in § 173.27(c).  

Q2. Section 173.4a(e)(3) requires that for liquid hazardous materials, the intermediate packaging must contain sufficient absorbent material and §173.4a(e)(3)(i) requires that such material will absorb the entire contents of the inner packaging.  You provide a scenario where a tube containing a liquid hazardous material is contained inside of an inner packaging, which is placed into an intermediate packaging.  You ask if the absorbent material may be placed surrounding the tube.

A2. The answer is yes.  As required by § 173.4a(e)(3), the absorbent material must be placed outside the of the inner packaging within the intermediate packaging.  In the scenario described, the tube may be considered the inner packaging.  As such, the absorbent material may be placed surrounding the tube within the next level of packaging.  

I hope this satisfies your request.


Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division

173.4a, 173.4a(a)(4), 173.27(c), 173.27(c)(3)(i), 173.4a(e)(3), 173.4a(e)(3)(i)

Regulation Sections

Section Subject
173.27 General requirements for transportation by aircraft
173.27 General requirements for transportation by aircraft
173.4a Excepted quantities
173.4a Excepted quantities
173.4a Excepted quantities