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Interpretation Response #16-0031 ([Container Technologies Industries, LLC.] [Mr. Steve Fielden])

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

Interpretation Response Details

Response Publish Date:

Company Name: Container Technologies Industries, LLC.

Individual Name: Mr. Steve Fielden

Location State: TN Country: US

View the Interpretation Document

Response text:

August 18, 2016

Mr. Steve Fielden
President/COO
Container Technologies Industries, LLC
375 Marcum Parkway
Kelenwood, TN  37755

Reference No. 16-0031

Dear Mr. Fielden:

This responds to your February 19, 2016 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), the International Atomic Energy Agency (IAEA) Regulations for the Safe Transport of Radioactive Material TS-R-1, and associated IAEA advisory material TS-G1.1.  Specifically, you ask several questions concerning the target for free drop tests on Type A packages.  Your questions are paraphrased and answered below:

Q1. You state that the IAEA advisory material TS-G1.1 provides more detailed guidance on target construction than currently found in § 173.465(c)(5) and in the TS-R-1.  Given the guidance in TS-G1.1 you ask if it would be unacceptable to have a target constructed by simply placing a loose steel plate over a paved or gravel surface with unknown soil compaction and unknown soil density as flexure and deformation of the target in the vertical direction would not be in conformance with the requirements of an unyielding surface.  

A1.  The IAEA advisory material TS-G1.1 is not a document currently incorporated by reference into the 49 CFR.  The HMR does not specifically authorize or prohibit particular methods of preparing or assembling the target for Type A package drop tests, but rather provides criteria that must be met.  Section 173.465(c)(5) requires a target to be a flat horizontal surface of such mass and rigidity that any increase in its resistance to displacement or deformation upon impact by the specimen would not significantly increase the damage to the specimen.  It is the opinion of this Office that this target configuration may be acceptable in some cases, such as for packages with a small gross mass, but unacceptable for packages with a larger gross mass.  The requirement in § 173.465(c)(5) is that the target be of such mass and rigidity that increasing its resistance to displacement or deformation upon impact by the specimen would not significantly increase the damage to the specimen.  Said another way, the target must be of sufficient mass and rigidity that if you were to change the physical properties of the target by adding more mass to or increasing the rigidity of the target there would not be a significant increase in the damage to the specimen.    

Q2. You quote guidance from the IAEA advisory material TS-G1.1 that states “the combined mass of steel and concrete should be at least 10 times that of the specimen to be dropped on it.” You ask if given this guidance, a free drop test target constructed using a steel plate anchored and embedded in a thick concrete slab with a reaction mass greater than 10 times the mass of the specimen to be tested can be considered in compliance with the requirements of an unyielding surface.  Specifically, you ask if a 1 inch steel plate anchored to a thick concrete slab with a total reaction mass of 350,000 lbs can be considered a suitable target for drop test specimens up to 35,000 lbs.

A2.  As stated in A1 above, § 173.465(c)(5) requires a target to be a flat horizontal surface of such mass and rigidity that any increase in its resistance to displacement or deformation upon impact by the specimen would not significantly increase the damage to the specimen. It is impossible for this Office to determine that the target mentioned in Q2 would be compliant in all possible testing scenarios. If the properties of the specimen being tested (e.g. material of construction, design configuration, etc) are such, that when utilizing the specific target mentioned in Q2, that a change in the physical properties of the target by adding more mass to or increasing the rigidity of the target would result in a significant increase in the damage to the specimen then that target would not be compliant with the requirements in § 173.465(c)(5).   

I hope this information is helpful.  Please feel free to contact this Office if we can be of further assistance.

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.465(c)(5),

Regulation Sections

Section Subject
173.465 Type A packaging tests