28 Spray November 2016 Steven Charles Hunt President, ShipMate, Inc. From here to there: Topics in Transportation Strong outer packaging & conditions normally incident to transportation I The U.S. Dept. of Transportation’s (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA) refers to “strong outer packaging” and “conditions normally incident to transportation” throughout Title 49, Code of Federal Regulations (CFR), subchapter C Hazardous Materials Regulations (HMR). In particular, 49 CFR §173.306, the section applicable to aerosols and limited quantities of compressed gases, refers to “strong outer packaging” fourteen times. I counted the term “conditions normally incident to transportation” in the HMR no fewer than 30 times. Interestingly enough, one term is used to define the other. Regulation 49 CFR §171.8 defines a “strong outer packaging” as: …the outermost enclosure that provides protection against the unintentional release of its contents. It is a packaging that is sturdy, durable, and constructed so that it will retain its contents under normal conditions of transportation. In addition, a strong outer packaging must meet the general packaging requirements of subpart B of part 173 of this subchapter but need not comply with the specification packaging requirements in part 178 of the subchapter. For transport by aircraft, a strong outer packaging is subject to §173.27 of this subchapter. The terms “strong outside container” and “strong outside packaging” are synonymous with “strong outer packaging.” Curiously, however, DOT never defines the term “conditions normally incident to transportation.” Strong Outer Packaging A “strong outer packaging” must be…sturdy, durable and constructed so that it will retain its contents….and meet the general packaging requirements…of 49 CFR 173 subpart B and, for transport by air, meet the requirements of 49 CFR §173.27. 49 CFR §173.24 (General requirements for packagings and packages), section 173.24(b) requires that: There will be no identifiable (without the use of instruments) release of hazardous materials to the environment; The effectiveness of the package will not be substantially reduced. For example, impact resistance, strength, packaging compatibility, etc. must be maintained for the minimum and maximum temperatures, changes in humidity and pressure, and shocks, loadings and vibrations, normally encountered during transportation; There will be no mixture of gases or vapors in the package which could, through any spontaneous increase of heat or pressure, significantly reduce the effectiveness of the packaging; and There will be no hazardous material residue adhering to the outside of the package during transport. Certainly, the requirements listed above seem logical and Item (b) seems reasonable, as well. However, it is much harder to quantify the minimum and maximum temperatures, changes in humidity and pressure, and shocks, loadings and vibrations that are normally encountered during transportation. Transportation by Air Regulation 49 CFR §173.27(c) requires that packagings be designed and constructed to prevent leakage that may be caused by changes in altitude and temperature during transportation aboard aircraft. These provisions also require that: Packaging for which retention of liquid is a basic function must be capable of withstanding without leakage the greater of: (i) An internal pressure which produces a gauge pressure of not less than 75 kPa (11 psig) for liquids in Packing Group III of Class 3 or Division 6.1; or 95 kPa (14 psig) for other liquids; or (ii) A pressure related to the vapor pressure of the liquid to be conveyed, determined by one of the following: (A) The total gauge pressure measured in the receptacle (i.e., the vapor pressure of the material and the partial pressure of air or other inert gases, less 100 kPa (15 psia)) at 55°C (131°F), multiplied by a safety factor of 1.5; determined on the basis of a filling temperature of 15°C (59°F) and a degree of filling such that the receptacle is not completely liquid full at a temperature of 55°C (131°F) or less; (B) 1.75 times the vapor pressure at 50°C (122°F) less 100 kPa (15 psia); or (C) 1.5 times the vapor pressure at 55°C (131°F) less 100 kPa (15 psia). Regulation 49 CFR §173.27(d) requires the body and closures of any packaging to be constructed such that they will adequately resist the effects of temperature and vibration occurring in conditions normally incident to air transportation. There it is again: normally incident to transportation. Conditions Normally Incident to Transportation I poured through the plethora of U.S. DOT interpretations trying to find a definition of the term “conditions normally
Spray November 2016
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