Western Poly Drums, Inc. — Hazardous Materials Safety Interpretation

Page 1.. U.S.Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 MAR 1 5 2000 Mr. Floyd A. Whitney President Ref. No: 00-0024 Western Poly Drums, Inc. 8727 Rochester Ave. Rancho Cucamonga, CA 91729-4200 Dear Mr. Whitney: This is in response to your letter of January 25, 2000, requesting clarification of the requirements for leakproof testing of non-bulk packagings under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically you ask whether you may follow the methods outlined in Appendix B to Part 178--Alternative Leakproofness Test Methods, as an alternative to the testing procedure required by § 178.604. The answer is yes. As stated in § 178.604(d) Test method, "other methods, at least equally effective, may be used in accordance with appendix B of this part." I hope this information is helpful. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 000024#

Page 2POLY FIBRE STEEL WESTERN POLY WHY NOT PLACE YOUR NEXT ORDER ON-LINE? www.WesternPoly.com DRUMS, INC. A COMPLETE LINE OF U.N. CONTAINERS & TANKS Hattie L. Mitchell Research and Special Program U.S. Department of Transportation 400 Seventh Street, S.W Washington, D.C. 20590 January 10, 2000 Subject: Steel drum re-con leek proof test Dear, Hattie L. Mitchell Western Poly Drums, Inc. is going into re-con steel drums business. As I understand CFR 49, #173.28 & 178.604 (d) leak proof test I can use Ne are also going to have the drums third party tested each year Appendix B (2) and (3) is this correct Please let me know as soon as possible if I am correct. Floyd A Whitney President 8727 ROCHESTER AVE., RANCHO CUCAMONGA, CA 91729-4200 (909) 466-9927 FAX 945-3075 -#