Total Quality Control Associates — Hazardous Materials Safety Interpretation

Page 1- of Transportation U.S.Department 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Special Programs Administration APA 1 1 2001 Mr. William C. Shreves Total Quality Control Associates Reference No.: 00-0237 4712 Woodward Ave. Downers Grove, IL 60515 Dear. Mr. Shreves: This is in response to your August 17, 2000 letter concerning the hydrostatic test prescribed in 49 CFR 178.605. Specifically, you state that one of your 2-inch closures also has a 3/4-inch closure in its center. You asked if the pressure applied into the packaging may be introduced through the 3/4-inch opening instead of adding another opening in the packaging. If the closure has been previously hydrostatical pressure tested, then this test method would be acceptable. If it has not been previously pressure tested, then the answer is no; the pressure may not be applied through the 3/4-inch opening. Section 178.602(a) and (e) requires that 1) each package and packaging must be closed in preparation for testing, and 2) the tests must be carried out on the packages prepared as if for actual shipment. I hope this satisfies your request. Sincerely, Hotte z, michell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2= : TOTAL QUALITY CONTROL ASSOCIATES 4712 Woodward Avenue William C. Shreves Downers Grove, Illinois 60515 President Telephone _orbir (030) 852-827 s118.605 August 17, 2000 Hydrostatic Pressure test Research and Special Programs Administration Office of Hazardous Material Standards (DHM-10) 00-0237 U.S. Department of Transportation 400 Seventh Street, S.W. Washington, DC 20590-0001 Dear Sirs, As a Quality Systems Consultant, I have clients in the non-bulk container industry. A asked. question regarding Subpart M, Section 178.605, Hydrostatic pressure testing has been It is understood that the samples must be tested with their closures in place. However, if one of the 2 inch closures also has a 3/4 inch closure included within the center of it, can the test pressure be introduced through this smaller opening? This method would preclude the necessity of introducing another opening in the container, for example, a fitting such as a tire valve with the stem removed. Thank you in advance for your cooperation. Respectfully, William C. Shee William C. Shreves T.Q.C.A.#

Page 3T.Q.C.A. WILLIAM C. SHREVES 4712 WOODWARD AVENUE PH DOWNERS GROVE, IL 60515-3335 403 00300 18 AUC Research and Special Programs Administration Office of Hazardous Material Standards (DHM-10) U.S. Department of Transportation 400 Seventh Street, S.W. Washington, DC 20590-0001 4 20590+0001 -#