{"operation":"document","citation":"00-0148","title":"Quality Control Department — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-06-28","effective_on":null,"summary":"00-0148 response to Quality Control Department concerning 178.603.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0148.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0148.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0148","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000148.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, D.C\nSpecial Programs\nResearch and\nAdministration\nJUN 28 2000\nMr. Colum O'Hara\nRef. No. 00-0148\nPhoenix Container, Inc.\nQuality Control Department\n1202 Airport Road\nN. Brunswick, New Jersey 08902\nDear Mr. O'Hara:\nThis is in response to your letter dated May 9, 2000, requesting clarification of the drop test\nprocedures for performance oriented packagings, such as 1A1 and 1A2 steel drums, under\n§ 178.603 (f)(1) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You\nstate that you were advised on May 8, 2000, by the Hazardous Materials Information Center that\nequilibrium could be reached by letting the contents of the package settle. Specifically, you ask if\nthis is an acceptable method to reach equilibrium inside a container once it has been drop tested.\nThere are several acceptable methods for achieving equilibrium between the internal and external\npressures of the container. These methods include: letting the package sit for a time to allow the\ncontents of the package to settle; or by drilling a hole into the vapor or air space to achieve\nequilibrium in the package after the drop test.\nI hope this answers your inquiry.\nSincerely,\nArn Hillis,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n178.603\n000148\n\n<<<PAGE 2>>>\n\nBoothe\nMay 9, 2000\n$178.603\nMr. Edward Mazzullo\nDirector of the Office of Hazardous Materials Standards\n00 - 0148\nU.S. DOT / RSPA - DHM - 10\n400 7* Street\nSW Washington, DC 20590\nPhoenix Container, Inc., is a metal container manufacturer, which produces metal\nDear Mr. Mazzullo,\nPhoenix Container, Inc.\ncontainers ranging in capacities from two gallon through six and a half gallons. A large\npercentage of containers produced by Phoenix Container, Inc., are performance\norientated packagings including both 1A1 and 1A2 packages. This facility has obtained\nthe Manufacturing Number-M5380 and has begun to test and certify its containers in\nconjunction to the Code of Federal Regulations Number 49.\nPhoenix Container, Inc., formally requests clarification in regards to the drop test, Statute\n178.603 (f) (I), prescribed in the 49 CFR. Specifically, this department petitions\nclarification in regards to how equilibrium is reached inside the container once it has been\ndropped.\nThis department had contacted the U.S. Department of Transportation, Hazardous\nMaterials Regulations Information Center, (800) 467-4922, on May 8, 2000, at 10:40\nclarification in regards to how equilibrium is reached inside the container once it has been\nA.M., to clarify Statute 178.603 (f) (1). Phoenix Container, Inc., specifically requested\ndropped. The information Phoenix Container, Inc., received from Ms. Lorena Alvarez,\nan Information Specialist for the U.S. DOT, suggested that equilibrium would be reached\nby letting the contents of the package settle. Ms. Alvarez further stated that the test is\ndesigned to see if a package is able to stand a spike in the internal pressure after it has\nbeen dropped.\nPlease indicate if the dropped container reaches equilibrium between the internal and\nexternal pressures if the container is left untouched and its liquid contents are allowed to\nsettle. Your guidance and decision will be greatly appreciated. Thank you in advance for\nyour time and cooperation in this matter.\nSincerely,\nO Har\nPhoenix Container, Inc.\nQuality Control Department\ncc: KS\nTB\n1202 Airport Rpite\nN. Brunswick, NJ 08902\nPhone\n732.247.6700\nFax\n732.247.0502","truncated":false,"body_characters":3509}