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Spray April 2016

April 2016 SPRAY 25 More than 135 companies hold these three special permits alone. Many of the other special permits incorporated into the final rulemaking pertain to acoustic emission (AE) and ultrasonic examination (UE) testing of cylinders and aerosols. Based on the requirements of DOT–SP 13601, the U.S. Dept. of Transportation (DOT) has proposed and implemented a requirement that, for containers with pressure relief systems, the upper bound of the functional range for a pressure relief system must be no greater than 80% of the minimum burst pressure or the recorded test pressure. This variation would require these containers to be marked as a ‘‘DOT 2P1.’’ These variations on a 2P container are equipped with some manner of pressure relief system (e.g., a rim-vent release device or a dome expansion device) that must function by a certain threshold level or within a certain pressure range, otherwise the container is rejected. In effect, these containers are designed to buckle to relieve pressure before bursting. For example, for a container built to DOT–SP 12573, the minimum pressure before the system buckles is 220psig (and if not equipped with a pressure relief system, the container may not burst below 320psig). The DOT has also adopted the standards for the modified DOT 2Q container found in DOT–SP 12573 as a variation on the DOT 2Q container design. This variation would be required to be marked as a ‘‘DOT 2Q1.’’ DOT has also adopted a 300psig minimum burst pressure for this modified 2Q container and requires buckling of the system at 75% of tested burst pressure (with a minimum burst test pressure of 300psig). DOT–SP 14503 also provides for a variation on the DOT 2Q container specification by authorizing construction of the container according to modifications to its manufacture and testing. DOT has adopted the standards for the modified DOT 2Q container found in DOT–SP 14503 as a variation on the DOT 2Q container design. This variation would be required to be marked as a ‘‘DOT 2Q2.” The revised provisions of 173.306(a)(3)(ii) list the authorized metal aerosol containers and associated pressure limitations in Table 2. From here to there: Topics in Transportation Authorized plastic aerosol containers and associated pressure limitations, outlined in 49 CFR 173.306(a)(4)(ii) are shown in the Table 3. Foodstuffs or soaps with soluble or emulsified compressed gas are authorized in non-refillable metal or plastic containers not to exceed 1L (61.0 cubic inches) capacity provided the pressure in each container does not exceed 140psig at 54.4°C (130°F) unless authorized by variation of a container type. For pressures ranging from greater than 140psig to 160psig, a variation DOT 2P1 or DOT 2Q2 (§§ 178.33(c) and (d) of 49 CFR subchapter C, respectively) container must be used. However, the pressure of the contents in the container may not be greater than 150psig at 23.9°C (75°F). Plastic containers may only contain Division 2.2 non-flammable soluble or emulsified compressed gas. Metal or plastic containers must be capable of withstanding, without bursting, a pressure of at least one and one-half times the equilibrium pressure of the contents at 54.4°C (130°F). The authorized aerosol Containers for foodstuffs and soaps are shown in Table 4. These are just some of the many requirements from the many special permits that have been incorporated into the HMR through the DOT’s rulemaking. A copy of the final rule is available from ShipMate, Inc. at +1 (310) 370-3600 or copying the following URL into your browser: https://www.gpo.gov/fdsys/pkg/FR-2016-01-21/pdf/2016- 00780.pdf Spray Table 2. Authorized Metal Aerosol Containers If the gauge pressure (psig) at 54.4°C (130°F) is… Authorized container 140 or less Non-DOT specification, DOT 2P, DOT 2Q, DOT 2Q1 greater than 140 but not exceeding 160 DOT 2P, DOT 2Q, DOT 2Q1 greater than 160 but not exceeding 180 DOT 2Q, DOT 2Q1 not to exceed 210 DOT 2Q1 Table 3. Authorized Plastic Aerosol Containers If the gauge pressure (psig) at 55°C (131°F) is… Authorized container less than 140 Non-DOT specification, DOT 25 140 or greater but not exceeding 160 DOT 2S Table 4. Authorized Aerosol Containers for Foodstuffs & Soaps If the gauge pressure (psig) at 54.4°C (130°F) is… Authorized container Not exceeding 140 Non-DOT specification, DOT 2P, DOT 2P1, DOT 2Q, DOT 2Q2 greater than 140 but not exceeding 160 DOT 2P, DOT 2P1, DOT 2Q, DOT 2Q2 greater than 160 but not exceeding 180 DOT 2Q, DOT 2Q2


Spray April 2016
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