Honeywell International Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department 40D Seventh Street, S.W. of Transportation Washington, D.C. 20590 esearch and Administration pecial Program JAN 3 1 2001 Ms. Barbara Konrad Ref. No: 00-0247 Honeywell International Inc. 101 Columbia Road Morristown, NJ 07962 Dear Ms. Konrad: This is in response to your letter regarding closure procedures for a drum under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask whether it is permissible to deviate from a manufacturer's recommended closure torque for a specification drum if there is sufficient evidence collected by the shipper that the recommended torque could result in a leaking package. You provided the following scenario: You use a UN 1H1 drum manufactured by Russell-Stanley. This is the only drum on the market suitable for your product. The recommended torque closure from the manufacturer is 25 foot-pounds with no allowable tolerance range. You found that when closures of filled drums are torqued to 25 foot-pounds, severe cupping of the drum closure results. You believe this makes the drums unsuitable and unsafe for transportation. When you checked older versions of the same manufacturer closure instructions for the same drum, a closure torque of 20 foot-pounds was recommended. Internal studies confirm that closing the drums to a torque of 20 foot-pounds, significantly improves closure, does not deform the bung and results in an overall safer package. If deformation of a closure is occurring, the manufacturer should be made aware of the deficiency. You should request that the manufacturer revise its notification to customers to specify an appropriate closure torque. Alternatively, you may use Variation 5 (§ 178.601(g)(5))) to change the torque closure on a UN certified drum. As provided by this variation, a closure device may differ from a tested design type provided an equivalent level of performance is maintained and qualifying tests (leakproofness test, ydrostatic pressure test and the stacking test) are successfully passed. A test report must b eveloved and attached to the original test report or closure notificatior I hope this information is helpful. Sincerely, Edom I. Azullo Director 178,509 Iff of Haradous Materials Slandards 000247#

Page 2SEP-86-2000 15:45 ALLIEDSIGNAL MATLS MGMT P.002/003 Honeywell Honeyweil Morristown, NJ 07962-1057 P.O. Box 1057 La Valle 8178 348 September 5, 2000 Asse no caros hir Drums US Department of Transportation Research and Special Programs Administration 00 - 0247 Office of Hazardous Materials Standards (DHM-10) 400 Seventh Street, SW Washington, DC 20590-0001 Re: Request for Interpretation on Allowable Deviations from Drum Closure Instructions Dear Diane, Thank you for speaking with me last week regarding the closure of drums in a manner that does not precisely correspond to the packaging manufacturer closure instructions. I was very interested to learn of your recent discussions with the National Association of Chemical Distributors (NACD) pertaining to this very issue. As we discussed, I am formally requesting a written response from your office on the following question: Is it permissible to deviate slightly from a manufacturer's recommended closure torque for a 1H1 specification drum if there is sufficient evidence collected by the shipper that the recommended torque could result in a leaking package? The packaging in question is a Russell-Stanley 55 DELCON 0505 NAT EC. This is the only drum on the market suitable for our product in its intended application. The recommended torque closure from the manufacturer is 25 foot-pounds with no allowable tolerance range (i.e. +/- 5 foot-pounds). We have found that when closures of filled drums are application torqued to 25 foot-pounds, per the drum feel this makes the drums unsuitable and unsafe for transportation. Internal studies manufacturers recommendation, severe cupping of the drum closure results. We confirm that closing the drums to a torque of 20 foot-pounds, significantly improves closure, does not deform the bung and results in an overall safer package. We have reached this conclusion after careful analysis of both the packaging and the manufacturer's closure instructions. Our packaging protocol requires the placement of a floor-length clear plastic bag over the filled drum to maintain exterior instructions (25 foot-pounds of torque), liquid vapor escapes from the drum bungs cleanliness. When the drums are filled and closed according to the manufacturer's over a period of a few days. We observed this from cordensation on the drum top surface beneath the clear bag. After one week we noticed that multiple bungs were#

Page 3•. SEP-06-2000 15:45 ALLIEDSIGNAL MATLS MGMT P.003/003 cracked along the thread edge, allowing even more liquid vapor to escape. We therefore concluded that 25 foot-pounds of torque is not appropriate for this particular drum in this particular application. Going back to older versions of the same manufacturer closure instructions for the same drum, a closure torque of 20 foot-pounds was recommended. We conducted Internal tests, similar to the ones described above, using 20 foot-pounds and determined that the closure of the drum was much better. To further test our hypothesis, we performed leakproofness testing (in accordance with 49 CFA 178.604(d) and Appendix B to Part 178), on several drums closed to 20 foot- pounds of torque. All of the drums passed the test. We therefore can assert that lowering the closure torque from 25 to 20 foot pounds results in a much better, safer seal of the drum bung. We have spoken informally to the Hazmat information line (Diane) on this topic and have been advised that in our case, closing the bung to 20 foot-pounds (as opposed to the manufacturer's recommended 25 foot-pounds) would not be a violation of the hazardous materials regulations. We would like a formal interpretation to include in our files for this product packaging. I am available to answer any follow-up questions you might have and | look forward to hearing from your office shortly.. I can be reached at 973-455-4009. Thank you in advance for your help with this issue. Sincerely,* Barbara Konrad Manager, Transportation Regulatory Affairs Honeywell International Inc. : 101 Columbia Road : Morristown, NJ 07962 973-455-4009 (phone) 973-455-5391 (fax) cc: Mike Dodd Norma Sibley#