{"operation":"document","citation":"01-0115","title":"gh Package & Product Testing and Consulting, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-11-26","effective_on":null,"summary":"01-0115 response to gh Package & Product Testing and Consulting, Inc. concerning 178.603.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0115.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0115.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0115","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010115.pdf","body":"<<>>\n\n... .\nJ.S. Department\n400 Seventh St., S.W.\nof Transportatior\nWashington, D.C. 20590\nSpecial Programs\nResearch and\nAdministration\nNOV 26 2001\nMr. H. Perry Hock\nRef. No: 01-0115\nTechnical Director\ngh Package & Product Testing\nand Consulting, Inc.\n325 Commercial Drive.\nFairfield, OH 45014\nDear Mr. Hock:\nThis is in response to your letter and subsequent telephone conversation with Diane LaValle of my staff,\nrequesting clarification of the requirements for testing of packagings under the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as\nfollows:\nQ1. You are testing a combination packaging consisting of 4 one-gallon plastic inner receptacles in a\nfiberboard box. The manufacturer wants the packaging to be certified at the highest possible maximum\ngross weight. When you raise the weight of the packaging by adding lead shot or sand, the packagings\nfail. If they are tested with the actual high specific gravity (SG) material that will be transported, they\npass. You ask if you may use the formula provided in § 178.603(e)(2)(ii) but work it backwards to\ndetermine the specific gravity to which a packaging may be certified. In other words, you want to\ndetermine the maximum height at which a packaging will pass the drop test and then work backwards to\ndetermine the corresponding SG. You ask what maximum gross weight should be marked on a\npackaging where the packaging was filled with water and passed a drop test at a height of 4.416 feet.\nYou propose to perform the necessary calculation as follows:\nPacking Group II: SG × 3.3 feet [§ 178.603(e) (2)(ii)]\nSG = 4.416 feet + 3.3 feet\nSG = 1.33\nA. You may determine specific gravity by using the equation in § 178.603(e)(2)(ii) in reverse. In your\nscenario using 1.33 SG, 4 one-gallon containers plus the tare weight of 3 pounds, the packaging may be\ncertified to 23.1 kg. This is calculated by taking the rated capacity of the packaging in liters (4 gallons =\n15.14 liters) times the specific gravity (1.33 as calculated above) to get the maximum gross weight in\nkilograms [§ 173.24(b)(3)]. We note that this calculation does not leave any margin for error; the\npackage failed at an incremental increase in drop height. Since each packaging must be capable of\npassing all the performance tests at any time during transportation, we recommend that you reduce the\nauthorized specific gravity some reasonable amount so as to provide a greater margin for variation in\nperformance of the production packagings.\n8.403\n010115\n\n<<>>\n\n.. •\nQ2. May the maximum gross weight of a packaging be marked to 1 decimal place or must it be a whole\nnumber rounded down?\nA. The maximum gross weight for a packaging may appear as a whole number rounded down or may\nappear rounded to the first decimal.\nQ3. May the specific gravity be marked on a packaging to 2 decimal places? How should it be\nrounded? Should the actual SG be used to determine drop height or the rounded down SG?\nA. As provided by § 178.503(a)(4)(i), single packagings intended to contain liquid are marked with the\nspecific gravity rounded down to the first decimal and may be omitted when the specific gravity does not\nexceed 1.2. The actual SG should be used to determine drop height.\nI hope this information is helpful.\nSincerely,\nDirector, Office of Hazardous\nMaterials Standards\n\n<<>>\n\ngh Package\nJgh\n& Product\nFairfield, OH 45014\n325 Commercial Dr.\nPhone (513) 870-0080\nFax (513) 870-0017\nTesting and\nConsulting, Inc.\n335 W. Melinda Lane\nPhoenix, AZ 85027\nPhone (623) 869-8008\nFax (623) 869-8003\nMay 3, 2001\nEdmonson\nTo:\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\n$ 172.312\nU.S. DOT/RSPA (DHM-10)\n400 7th Street S.W.\nWashington, DC 20590-0001\n3118.603\nFrom: Mr. H. Perry Hock\nMarking\n+ Testing\ngh Package & Product Testing and Company\nTechnical Director\n01-0115\nSubject: Non-bulk performance-oriented packaging.\nDear Mr. Mazzullo,\nI have several questions regarding marking and the testing of non-bulk packagings.\nThe pack consists of 4 plastic one-gallon jugs filled with windshield wiper fluid. The client\napproach to determine the highest SG allowed to be placed in it?\nE.G. The packs pass at 53 inches but not 54. Since 53 is less than group I but more than\ngroup II, We would use the group Il formula: SG x 3.3 feet (39.6 inches) = 4.416 feet (53\nwe can then rewrite the formula:\nSG =\n4.416 Feet\n3.3 Feet\nSG = 1.33\nNow using 1.33 SG, and the packaging consists of 4, 1-gallon containers, and the tare weight\npfile packaging is 3lbs, what would be the appropriale weight to be marker on the 40\n1.33 × 8.43 (weight of one gallon of water) = 11.21 Ibs. per bottle\n4 bottles x 11.21 Ibs. = 44.84 Ibs. just for the contents\n44.84 Ibs. + 3 1bs. of packaging = 47.84 Ibs. (21.7 kg)\nEd Mazzullo Letter 5-3-01\n\n<<>>\n\nPage 2\nQuestion 2:\nind testing of non-bulk pack\nQuestion 3\nMay the specific gravity of the material be marked on the pack to 2 decimal places? If the SG\ncannot be marked to two decimal places, how should it be rounded? How should it be tested\nrounded SG?\nand to what drop height? Should the actual SG be used for the drop height or the new,\nThis question may seem like it does not have merit until you consider the impact it has on\nshould be marked on the drum? If it is to be marked to a single decimal rounded down, the\nshipper can loose more than 4 gallons per drum.\nQuestion 4\nThe elient submits a pack of 4 metal 1-gallon containers that are filled with water. Water's\nSG is 1.0. The SG of the product they want to put inside of the pack is 1.18. Both fall under\nproduct. What drop height should be used to compensate for the weight difference? If the\nthe 1.2 cutoff to use, but the tested pack weighs 5.4 Ibs. less than the package with the actual\ntested. If the drop height is altered to a higher drop height, then the pack can be marked\ndrop height is not altered, then theoretically the pack must be marked with the weight\nsame\nwith the appropriate ship weight - which would be 2.4 kg higher.\nSimilar scenario:\nparty test lab that their 4G pack will weigh no more than 24 Ibs. when shipped. When we\nA client has a 4G combination pack with plastic inners for liquids. They tell us, the third\nreceive the samples filled with wiperfluid, the packs weigh 18 Ibs. What is the correct way\nof determining the drop height for this pack? Can a ratio be used?\nwould be 48 inches.\nExample: shipped weight is 40 Ibs. but the tested weight is 36 Ibs. The drop height for 40 Ibs.\n\n<<>>\n\n-\n.::\nPage 3\nThe ratio would be:\nProduct Ship Weight\nNew Drop Height\nTest Pack Weight\nRequired Drop Height\nAnd then rewritten as:\nProduct Ship Weight × Required Drop Height\nTest Pack Weight\n= New Drop Height\n40Ibs.x 48 Inches\n36lbs.\n- = 53.3 Inches\nI realize the drop height can never be lower than the required drop height but would this be\nacceptable for determining a pack's drop height when no specific gravity is given?\n7\nletter, please call me at 513.870.0080\nI look forward to your response: If you need clarification or have questions regarding this\nYours Truly,\nH. Perry Hock\nTechnical Director\ngh Package & Product Testing and Consulting, Inc.\nHPH/hph","truncated":false,"body_characters":7200}