{"operation":"document","citation":"01-0040","title":"HMT Associates, L.L.C. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-02-28","effective_on":null,"summary":"01-0040 response to HMT Associates, L.L.C. concerning 178.504.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0040.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0040.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0040","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010040.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nspecial Programs\nAdministration\nFEB 28 2001\nMr. E.A. Altemos\nRef. No. 01-0040\nHMT Associates, L.L.C.\n1850 K Street, N. W.\nSuite 200\nWashington, DC 20006-3500\nDear Mr. Altemos:\nThis is in response to your letter of February 7, 2001, regarding the standards for UN specification\ndrums found in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically,\nyou inquire about the opening size requirements distinguishing a non-removable head drum (e.g., 1A1)\nfrom a removable head drum (e.g., 1A2) found in § 178.504.\nYou describe a stainless steel drum with all welded construction except for a short, 20 mm high neck\nthat is 72 mm in diameter (inside). This is welded to the top of the drum. A flat, stainless steel plate\nand gasket covers the hole and is secured with a circumferential clamp held by two bolts through the\nears of the clamp. The flat plate on top has two openings of not more that 18.3 mm through which the\ndrum is filled and emptied. You ask if this drum conforms to the requirements of § 178.504(b)(5),\nwhich limits the diameter of openings on non-removable, 1A1 drums to 70 mm.\nThe answer is no. The 72 mm neck on the drum constitutes an opening, even though the filling and\nemptying of the drum occurs through smaller holes drilled into the plate covering the opening, because\nthe plate covering the neck is removable. We recommend certifying this drum as a 1A2 removable\nhead drum or applying for an approval in accordance with § 178.601(h) to permit an opening larger\nthan 70 mm.\nI hope this satisfies your request.\nSincerely,\ntion Aroly\nfor John A. Gale\nTransportation Regulations Specialist\nOffice of Hazardous Materials Standards\nHINNIN\n010040\n\n<<<PAGE 2>>>\n\nJohnsen\n§ 118.504\nHMT ASSOCIATES, L.L.C.\nSteel Drums\n1850 K STREET, N.W.\nWASHINGTON, D.C. 20006-3500\nSUITE 200\n01-0040\nE.A. ALTEMOS\nPATRICIA A. QUINN\n(202) 463-3511\nGORDON ROUSSEAU\nFACSIMILE (202) 463-3512\nWRITER'S DIRECT DIAL NUMBER\n(202) 463-3511, Ext. 11\nFebruary 7, 2001\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous\nMaterials Standards (DHM-10)\nResearch and Special Programs\nAdministration\nDepartment of Transportation\nWashington, D.C. 20590-0001\nDear Mr. Mazzullo:\nThis is to request confirmation that a steel drum constructed as described herein is considered\nto be a non-removable head (1A1) drum in accordance with the provisions of § 178.504 of the\nHazardous Materials Regulations (\"the HMR\"; 49 CFR Parts 171-180).\nThe drum concerned is a high-integrity (hydraulic test pressure of 820 kPa), stainless steel\ndrum of all welded construction (except as noted herein). A short neck, approximately 20mm high,\nand 72 mm in diameter (inside), is welded to the top of the drum. A flat, stainless steel plate is\nplaced on a gasket installed over the lip at the top of the neck, and the assembly held (\"sandwiched\")\ntightly together by a circumferential clamp, the halves of which are secured together by two 3/8 x\n2 inch bolts inserted through ears on opposite sides of the clamp. In the flat plate are two or more\nopenings with a diameter of not more than 18.3 mm through which the drum is filled and emptied.\nThese openings may be closed either by a threaded plug, or by a valve arrangement threaded into the\nopening. The neck and any valving arrangement that may be installed is protected by a stainless steel\ncollar welded to the top of the drum.\nAs you know, § 178.504(b)(5) provides that \"[o]penings for filling, emptying and venting\nin the bodies or heads of non-removable head (1A1) drums may not exceed 7.0 cm. Drums with\nlarger openings are considered to be of the removable head type (IA2).\" The word \"openings\" in\n\n<<<PAGE 3>>>\n\nHMT ASSOCIATES, L.L.C.\nMr. Edward T. Mazzullo\nFebruary 7, 2001\nPage 2\nthe second sentence can only be interpreted as referring to openings serving the same purposes as\nthose addressed in the first sentence; that is, \"openings for filling, emptying and venting\" the drum.\nConsequently, since the openings used for filling and emptying the stainless steel drum described\nherein do not exceed 7.0 cm, the drum would meet the requirements for designation as a non-\nremovable head (1A1) drum.\nPlease confirm that my understanding is correct that the steel drum described above meets\nthe requirements for a non-removable head (1A1) drum for purposes of application of the HMR.\nYour early reply would be most appreciated. Thank you for your consideration, and please do not\nhesitate to contact me if you have questions or require additional information regarding this matter.\nSincerely,\nE. A. Altemos","truncated":false,"body_characters":4650}