What is Approval CA199807017?
It is a special permission from the Competent Authority of the United States to ship a hazardous material in different but equally safe packaging using the packaging specified in the International Civil Aviation Organization’s Technical Instructions (ICAO Technical Instructions).
Why was an approval necessary?
Argonne National Laboratory wanted to transport very small portions of non-hazardous biological samples to and from its Argonne Illinois laboratory for testing purposes. These samples were frozen in flammable and/or non-flammable gas and kept cold in a specially-designed container. The ICAO Technical Instructions require gases to be packaged in a cylinder. The regulations further require marking to indicate the cylinder has passed pressure tests. The gases are in a frozen state and will not go into a cylinder as required. Argonne Laboratory uses a specially-designed drum to ship the frozen gas and samples. The shipping container used is in conflict with the hazardous materials regulations; therefore, the authorization is required.
It is time to study the Approval so that we understand what the allowable variation is. We also need to know when the ICAO Technical Instructions regulations apply to a shipment.
1. APPROVAL HOLDER:
Argonne National Laboratory
9700 South Cass Avenue
Argonne, Illinois 60439
Item # 1 tells us that Argonne National Laboratory at 9700 South Cass Avenue, Argonne, Illinois 60439 is the approval holder.
2. REGULATORY AUTHORITY: Part 1; Paragraph 1.1.2 of the International Civil Aviation Organization’s Technical Instructions for the Safe Transportation of Dangerous Goods by Air (ICAO TI).
Item # 2 tells us the authority to regulate hazardous material shipping by air in the United States is stated in Part 1 Paragraph 1.1.2 of the ICAO Technical Instructions.
3. SYNOPSIS: This approval authorizes the cargo air transport of small samples of biological macromolecules (e.g., proteins, enzymes, antibodies, ribosomes, non-restricted viruses, DNA, RNA, etc.) contained in a deeply refrigerated flammable or non-flammable gas and packaged in a “dry shipper” charged with liquid nitrogen.
Item # 3 recaps what the Approval authorizes. Small biological samples are frozen inside a flammable or
non-flammable gas and packaged in a dry shipper
charged with liquid nitrogen. Under certain controlled
conditions an alternate packaging is authorized.
4. BASIS: This approval is issued in response to Argonne National Laboratory’s request dated July 8, 1998 and additional information dated October 28, 1998 and October 22, 2002.
Item # 4 tells us that Argonne Laboratory requested the exception and provided additional data to the Research and Special Programs Administration of the U.S. Department of Transportation. By making the request, Argonne assumed the burden of proof in establishing the safety of the alternate packaging.