{"operation":"document","citation":"00-0247","title":"Honeywell International Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-01-31","effective_on":null,"summary":"00-0247 response to Honeywell International Inc. concerning 178.509.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0247.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0247.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0247","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000247.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\n40D Seventh Street, S.W.\nof Transportation\nWashington, D.C. 20590\nesearch and\nAdministration\npecial Program\nJAN 3 1 2001\nMs. Barbara Konrad\nRef. No: 00-0247\nHoneywell International Inc.\n101 Columbia Road\nMorristown, NJ 07962\nDear Ms. Konrad:\nThis is in response to your letter regarding closure procedures for a drum under the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask whether it is permissible\nto deviate from a manufacturer's recommended closure torque for a specification drum if there is\nsufficient evidence collected by the shipper that the recommended torque could result in a leaking\npackage. You provided the following scenario:\nYou use a UN 1H1 drum manufactured by Russell-Stanley. This is the only drum on\nthe market suitable for your product. The recommended torque closure from the\nmanufacturer is 25 foot-pounds with no allowable tolerance range. You found that\nwhen closures of filled drums are torqued to 25 foot-pounds, severe cupping of the\ndrum closure results. You believe this makes the drums unsuitable and unsafe for\ntransportation. When you checked older versions of the same manufacturer closure\ninstructions for the same drum, a closure torque of 20 foot-pounds was recommended.\nInternal studies confirm that closing the drums to a torque of 20 foot-pounds,\nsignificantly improves closure, does not deform the bung and results in an overall safer\npackage.\nIf deformation of a closure is occurring, the manufacturer should be made aware of the deficiency.\nYou should request that the manufacturer revise its notification to customers to specify an appropriate\nclosure torque. Alternatively, you may use Variation 5 (§ 178.601(g)(5))) to change the torque closure\non a UN certified drum. As provided by this variation, a closure device may differ from a tested design\ntype provided an equivalent level of performance is maintained and qualifying tests (leakproofness test,\nydrostatic pressure test and the stacking test) are successfully passed. A test report must b\neveloved and attached to the original test report or closure notificatior\nI hope this information is helpful.\nSincerely,\nEdom I. Azullo\nDirector\n178,509\nIff of Haradous Materials Slandards\n000247\n\n<<<PAGE 2>>>\n\nSEP-86-2000 15:45\nALLIEDSIGNAL MATLS MGMT\nP.002/003\nHoneywell\nHoneyweil\nMorristown, NJ 07962-1057\nP.O. Box 1057\nLa Valle\n8178 348\nSeptember 5, 2000\nAsse no caros\nhir Drums\nUS Department of Transportation\nResearch and Special Programs Administration\n00 - 0247\nOffice of Hazardous Materials Standards (DHM-10)\n400 Seventh Street, SW\nWashington, DC 20590-0001\nRe: Request for Interpretation on Allowable Deviations\nfrom Drum Closure Instructions\nDear Diane,\nThank you for speaking with me last week regarding the closure of drums in a\nmanner that does not precisely correspond to the packaging manufacturer closure\ninstructions. I was very interested to learn of your recent discussions with the\nNational Association of Chemical Distributors (NACD) pertaining to this very issue.\nAs we discussed, I am formally requesting a written response from your office on\nthe following question:\nIs it permissible to deviate slightly from a manufacturer's recommended\nclosure torque for a 1H1 specification drum if there is sufficient evidence\ncollected by the shipper that the recommended torque could result in a\nleaking package?\nThe packaging in question is a Russell-Stanley 55 DELCON 0505 NAT EC. This is\nthe only drum on the market suitable for our product in its intended application. The\nrecommended torque closure from the manufacturer is 25 foot-pounds with no\nallowable tolerance range (i.e. +/- 5 foot-pounds). We have found that when\nclosures of filled drums are application torqued to 25 foot-pounds, per the drum\nfeel this makes the drums unsuitable and unsafe for transportation. Internal studies\nmanufacturers recommendation, severe cupping of the drum closure results. We\nconfirm that closing the drums to a torque of 20 foot-pounds, significantly improves\nclosure, does not deform the bung and results in an overall safer package.\nWe have reached this conclusion after careful analysis of both the packaging and\nthe manufacturer's closure instructions. Our packaging protocol requires the\nplacement of a floor-length clear plastic bag over the filled drum to maintain exterior\ninstructions (25 foot-pounds of torque), liquid vapor escapes from the drum bungs\ncleanliness. When the drums are filled and closed according to the manufacturer's\nover a period of a few days. We observed this from cordensation on the drum top\nsurface beneath the clear bag. After one week we noticed that multiple bungs were\n\n<<<PAGE 3>>>\n\n•. SEP-06-2000\n15:45\nALLIEDSIGNAL MATLS MGMT\nP.003/003\ncracked along the thread edge, allowing even more liquid vapor to escape. We\ntherefore concluded that 25 foot-pounds of torque is not appropriate for this\nparticular drum in this particular application.\nGoing back to older versions of the same manufacturer closure instructions for the\nsame drum, a closure torque of 20 foot-pounds was recommended. We conducted\nInternal tests, similar to the ones described above, using 20 foot-pounds and\ndetermined that the closure of the drum was much better. To further test our\nhypothesis, we performed leakproofness testing (in accordance with 49 CFA\n178.604(d) and Appendix B to Part 178), on several drums closed to 20 foot-\npounds of torque. All of the drums passed the test. We therefore can assert that\nlowering the closure torque from 25 to 20 foot pounds results in a much better,\nsafer seal of the drum bung.\nWe have spoken informally to the Hazmat information line (Diane) on this topic and\nhave been advised that in our case, closing the bung to 20 foot-pounds (as\nopposed to the manufacturer's recommended 25 foot-pounds) would not be a\nviolation of the hazardous materials regulations. We would like a formal\ninterpretation to include in our files for this product packaging.\nI am available to answer any follow-up questions you might have and | look forward\nto hearing from your office shortly.. I can be reached at 973-455-4009. Thank you\nin advance for your help with this issue.\nSincerely,*\nBarbara Konrad\nManager, Transportation Regulatory Affairs\nHoneywell International Inc.\n:\n101 Columbia Road\n:\nMorristown, NJ 07962\n973-455-4009 (phone)\n973-455-5391 (fax)\ncc: Mike Dodd\nNorma Sibley","truncated":false,"body_characters":6393}