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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 #17-0038

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

Interpretation Response Details

Response Publish Date:

Company Name: RASIRC

Individual Name: Mr. Ryan Woon

Location State: CA Country: US

View the Interpretation Document

Response text:

September 27, 2017
Mr. Ryan Woon
Analytical Services Supervisor
7815 Silverton Avenue
San Diego, CA  92126
Reference No. 17-0038
Dear Mr. Woon:
This letter is in response to your April 12, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipment of hydrogen peroxide by air.  You describe a scenario where “UN3098, Oxidizing liquid, corrosive, n.o.s. (hydrogen peroxide), 5.1, II” is being shipped in 250–750 mL containers that have a pressure relief device installed to open when reaching an internal pressure of 0.5 psi.  You further note that § 173.24(g) only allows the venting of packagings when air transport is not involved.  Specifically, you ask if the container described in your letter can be placed in an outer packaging (i.e., heat sealable pressure bag, United Nations (UN) rated drum or pressure vessel) and be shipped by air while in compliance with § 173.24(g). 
The answer is no.  As you note, § 173.24(g) of the HMR does not allow for venting of packagings when air transport is involved, except for shipments of cryogenic liquids and dry ice.  However, special permits may authorize relief from any requirement in the HMR, provided the applicant demonstrates an equivalent level of safety to that intended by the regulation.  To apply, you must submit an application to the Associate Administrator for Hazardous Materials Safety in conformance with the requirements prescribed in 49 CFR Part 107, Subpart B.  You may obtain information on the special permit application process from our Web site at, or by calling the Approvals and Permits Division at (202) 366-4511.
I hope this information is helpful.  Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.24(g), 107

Regulation Sections

Section Subject
173.24 General requirements for packagings and packages