Interpretation Response #20-0018
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mark B. Hawk
Location State: TN Country: US
View the Interpretation Document
Response text:
May 12, 2020
Mark B. Hawk
Packaging Management Council Coordinator
8116 Villa Grande Lane
Knoxville, TN 37938
Reference No. 20-0018
Dear Mr. Hawk:
This letter is in response to your February 25, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Type A packaging free drop test requirements.
We have paraphrased and answered your questions as follows:
Q1. You ask whether the reference to "safety features" in § 173.465(c) is referring to the parts of the Type A packaging that meet the performance requirements in § 173.412(j).
A1. The answer is yes. Section 173.465 details the requirements for Type A packaging tests, and to be considered successful, the packaging must meet the requirements of § 173.412(j).
Q2. You ask whether the requirement in § 173.412(j)(2) that the packaging prevent "a significant increase in radiation levels recorded or calculated at the external surfaces for the condition before the test" means that a significant decrease in radiation levels at the surface of the package does not need to be considered.
A2. The answer is yes. Section 173.412(j)(2) requires that the packaging will prevent "a significant increase in radiation levels recorded or calculated at the external surfaces for the condition before the test." If after the free drop test in § 173.465(c) there is not a significant increase in radiation levels at the external surface of the package, the package is considered to have met the requirements in § 173.412(j)(2).
Q3. You ask whether the requirement in § 173.412(j)(2) that the packaging prevent "a significant increase in radiation levels recorded or calculated at the external surfaces for the condition before the test" means that a significant increase or decrease in radiation levels at 1 meter from the surface of the package does not need to be considered as a performance standard.
A3. The answer is yes. See A2.
Q4. You ask whether the safety features of the Type A packaging need to be clearly identified prior to performing the free drop test in § 173.465(c) and any damage to the packaging be described on the test report after conducting the free drop test.
A4. The answer is yes, if testing a DOT Specification 7A packaging subject to § 173.465. Section 173.415(a)(1)(i) requires documentation of testing for packagings subjected to the physical tests of § 173.465, and if applicable, § 173.466. This documentation includes a detailed description of each test performed and the damage to each item of the containment system resulting from the test. For other Type A packaging, see §§ 173.415(b)-(d) for their requirements.
Q5. You ask how it is expected to determine the worst-case drop orientation for the Type A packaging to suffer maximum damage in § 173.465(c). You also ask if multiple drop orientations might be needed.
A5. As noted, § 173.465(c) requires that the Type A packaging be dropped onto the target so as to suffer maximum damage to the safety features. The Type A packaging and testing requirements are performance oriented and this Office is not able to determine the most appropriate orientation method for any one specific packaging configuration. There is no restriction to conducting multiple drop orientations to determine the worst-case drop orientation in order to meet § 173.465(c).
Q6. You ask when testing a Type A packaging containing fissile material, whether after performing the § 173.465(c)(2) free drop test, the packaging needs to be evaluated for any damage and then determine the orientation for maximum damage prior to performing the free drop test in § 173.465(c)(1).
A6. As required in § 173.465(c)(2), for packages containing fissile material, the free drop test in § 173.465(c)(1) must be preceded by a free drop from a height of 0.3 m (1 ft.) on each corner, or in the case of cylindrical packages, onto each of the quarters of each rim. After this test is conducted, the free drop test in § 173.165(c)(1) must be performed and the package must be dropped onto the target so as to suffer maximum damage to the safety features.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
173.465, 173.465(c), 173.465(c)(1), 173.465(c)(2), 173.412(j), 173.415(a)(1)(i), 173.415(b)-(d), 173.466