What does 49 CFR 173.181 (Pyrophoric materials (liquids)) require?
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According to 49 CFR 173.181, when the § 172.101 table requires a hazardous material to be packaged under this section, you must use only authorized non-bulk packagings. Specifically, the regulation permits the following packaging options:
1. Authorized Cylinders:
* Specification steel or nickel cylinders for compressed gases (except acetylene) with a minimum design pressure of 1206 kPa (175 psig).
* DOT 3AL aluminum alloy (6061-T6) cylinders with a minimum marked service pressure of 1,800 psig and a maximum water capacity of 49 liters (13 gal) for inorganic pyrophoric liquids (UN3194). Any preheating or heating of these cylinders is limited to a maximum temperature of 79.4 °C (175 °F).
* Cylinders equipped with valves must either have steel valve protection caps/collars or be overpacked in specified wooden, fiberboard, or plastic boxes. They must be secured against shifting and loaded so that pressure relief devices remain in the vapor space.
2. Combination Packagings with Small Inner Containers:
* Steel, aluminum, metal (other than steel/aluminum), wooden, or fiberboard boxes; steel, aluminum, metal (other than steel/aluminum), plywood, or fiber drums; or steel/aluminum jerricans enclosing no more than four strong, tight metal cans.
* These cans must have glass or metal inner receptacles not over 1 L (0.3 gallon) each, with positive screw-cap closures that are adequately gasketed or have alternative closures secured to prevent loosening from transport conditions like impact or vibration.
* Inner packagings must be cushioned on all sides with enough dry, absorbent, incombustible material to absorb the entire contents.
3. Combination Packagings with Larger Inner Cans:
* Steel, aluminum, metal (other than steel/aluminum), or fiber drums; steel or aluminum jerricans; or steel, aluminum, or metal (other than steel/aluminum) boxes not exceeding 220 L (58 gallons) capacity each.
* They must contain strong, tight inner metal cans not over 4.0 L (1 gallon) each, closed by positive means (not friction), with openings no larger than 25 mm (1 inch) in diameter, surrounded by noncombustible cushioning.
* The net quantity of pyrophoric liquids cannot exceed two-thirds of the rated capacity of the outer drum (e.g., a maximum of 147 L in a 220 L drum).
* Each layer of inner containers must be separated by a metal plate separator in addition to cushioning material.
4. Combination Packagings with Inner Stainless Steel Drums:
* Inner packaging: A 10-liter or 20-liter UN1A1 stainless steel drum certified to PG I, having a minimum wall thickness of 1.9 mm, four NPT or VCR openings (6.3 mm diameter each), and a center opening on the upper head sealed with a 316 stainless steel threaded closure (maximum diameter 68.3 mm). No more than two inner drums may be placed inside the outer drum.
* Outer packaging: A UN1A2 drum certified to the PG I performance level with a maximum capacity of 208 L (55 gal), a minimum wall thickness of 1.0 mm, and a top head closed with a steel closing ring having a minimum thickness of 2.4 mm.
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