Quality Control Department — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C Special Programs Research and Administration JUN 28 2000 Mr. Colum O'Hara Ref. No. 00-0148 Phoenix Container, Inc. Quality Control Department 1202 Airport Road N. Brunswick, New Jersey 08902 Dear Mr. O'Hara: This is in response to your letter dated May 9, 2000, requesting clarification of the drop test procedures for performance oriented packagings, such as 1A1 and 1A2 steel drums, under § 178.603 (f)(1) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that you were advised on May 8, 2000, by the Hazardous Materials Information Center that equilibrium could be reached by letting the contents of the package settle. Specifically, you ask if this is an acceptable method to reach equilibrium inside a container once it has been drop tested. There are several acceptable methods for achieving equilibrium between the internal and external pressures of the container. These methods include: letting the package sit for a time to allow the contents of the package to settle; or by drilling a hole into the vapor or air space to achieve equilibrium in the package after the drop test. I hope this answers your inquiry. Sincerely, Arn Hillis, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 178.603 000148#

Page 2Boothe May 9, 2000 $178.603 Mr. Edward Mazzullo Director of the Office of Hazardous Materials Standards 00 - 0148 U.S. DOT / RSPA - DHM - 10 400 7* Street SW Washington, DC 20590 Phoenix Container, Inc., is a metal container manufacturer, which produces metal Dear Mr. Mazzullo, Phoenix Container, Inc. containers ranging in capacities from two gallon through six and a half gallons. A large percentage of containers produced by Phoenix Container, Inc., are performance orientated packagings including both 1A1 and 1A2 packages. This facility has obtained the Manufacturing Number-M5380 and has begun to test and certify its containers in conjunction to the Code of Federal Regulations Number 49. Phoenix Container, Inc., formally requests clarification in regards to the drop test, Statute 178.603 (f) (I), prescribed in the 49 CFR. Specifically, this department petitions clarification in regards to how equilibrium is reached inside the container once it has been dropped. This department had contacted the U.S. Department of Transportation, Hazardous Materials Regulations Information Center, (800) 467-4922, on May 8, 2000, at 10:40 clarification in regards to how equilibrium is reached inside the container once it has been A.M., to clarify Statute 178.603 (f) (1). Phoenix Container, Inc., specifically requested dropped. The information Phoenix Container, Inc., received from Ms. Lorena Alvarez, an Information Specialist for the U.S. DOT, suggested that equilibrium would be reached by letting the contents of the package settle. Ms. Alvarez further stated that the test is designed to see if a package is able to stand a spike in the internal pressure after it has been dropped. Please indicate if the dropped container reaches equilibrium between the internal and external pressures if the container is left untouched and its liquid contents are allowed to settle. Your guidance and decision will be greatly appreciated. Thank you in advance for your time and cooperation in this matter. Sincerely, O Har Phoenix Container, Inc. Quality Control Department cc: KS TB 1202 Airport Rpite N. Brunswick, NJ 08902 Phone 732.247.6700 Fax 732.247.0502#