Black Forest Marketing, LLC — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and dministratio pecial Program AUG 1.8 2000 Mr. Tom Leftwich Ref. No. 00-0219 Black Forest Marketing, LLC 24 Vardy St. Suite 101-D Greenville, SC 29601 Dear Mr. Leftwich: This is in response to your August 8, 2000 letter regarding 49 CFR 178.504. Specifically, you ask if a closed head drum that is manufactured with a 3 inch opening meets the requirements of §178.504(b)(5). Section 178.504(b)(5) states that openings in the bodies. or heads of non-removable head (1A1) drums may not exceed 7.0 cm (3.0 inches) in diameter. As specified in § 171.10(a), the SI (metric) unit is the is provided for information only and is not intended to be the regulatory standard. Therefore, 7.0 cm egulatory standard. A U.S. standard or customary unit appearing in parentheses following the Si uni not 3.0 inches is maximum opening allowed on a UN 1A1 steel drum. Using the conversion factor in § 171.10(c) for length, a more precise U.S. standard measure would be 2.7559 inches. I hope this information is helpful. Sincerely, Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 000219 178.50y#

Page 2Gale Black Forest Marketing, LLC 8178.5046)5) Marking/ Steel Drums 00- 02/9 Mr. Edward Mazzullo Director, Office of Hazardous Materials Standards August 8, 2000 400 7* St. S.W. Washington, DC 20590 Dear Mr. Mazzullo, I would like to receive an interpretation from your office regarding Standards for steel drums, section 178.504 of 49CFR. I am particularly interested in section 178.504(b)(5) regarding the opening size of 1A1 drums - 7.0 cm vs. 3 inches - and how this may effect products manufactured in the US and in Europe. Presently, there are US manufacturers fabricating and marking containers UN1A1 with a 3" opening. This contradicts section 6.1.4.1.5 o" the UN Orange book. These vessels are being sold into the chemical industry for global listribution of hazardous materials. Is it not illegal to mark vessels UN1A1 with openings larger than 7.0 cm (2.755 inches) as indicated in the UN Orange book, as well as 49 CFR? Please refer to your letter to Mir. Robert Johnson of Florida Drum dated January ri, 1995; it states that the metric unit is the regulatory standard. Also, is it legal to ship conrainers marked UN1A1 with a 3" opening outside the US? We represent a European container manufacturer and would like to import product into the US. This manufacturer will only mark vessels with a 7.0 cm or less opening UN1A1; anything greater than 7.0 cm will be marked UN1A2. Attempting to mark vessels UNIAIW with a 3" opening is not permissible, according to our European UN competent authorities. What is your interpretatiun on this issue? We would like to offer our domestic customers i product that can legally be used in the US, as well as globally. We appreciate your ass stance and consideration in this matter, and look forward to your reply. Sincerely, Tony fake Tom Leftwich Black Forest Marketing, LLC 24 Vardry St. • Suite 101-D • Greenville, SC 29601 864-282-2301/2302 • Fax 864-282.1303 • blackforestmktg@aol.com#