gh Package & Product Testing and Consulting, Inc. — Hazardous Materials Safety Interpretation

Page 1... . J.S. Department 400 Seventh St., S.W. of Transportatior Washington, D.C. 20590 Special Programs Research and Administration NOV 26 2001 Mr. H. Perry Hock Ref. No: 01-0115 Technical Director gh Package & Product Testing and Consulting, Inc. 325 Commercial Drive. Fairfield, OH 45014 Dear Mr. Hock: This is in response to your letter and subsequent telephone conversation with Diane LaValle of my staff, requesting clarification of the requirements for testing of packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q1. You are testing a combination packaging consisting of 4 one-gallon plastic inner receptacles in a fiberboard box. The manufacturer wants the packaging to be certified at the highest possible maximum gross weight. When you raise the weight of the packaging by adding lead shot or sand, the packagings fail. If they are tested with the actual high specific gravity (SG) material that will be transported, they pass. You ask if you may use the formula provided in § 178.603(e)(2)(ii) but work it backwards to determine the specific gravity to which a packaging may be certified. In other words, you want to determine the maximum height at which a packaging will pass the drop test and then work backwards to determine the corresponding SG. You ask what maximum gross weight should be marked on a packaging where the packaging was filled with water and passed a drop test at a height of 4.416 feet. You propose to perform the necessary calculation as follows: Packing Group II: SG × 3.3 feet [§ 178.603(e) (2)(ii)] SG = 4.416 feet + 3.3 feet SG = 1.33 A. You may determine specific gravity by using the equation in § 178.603(e)(2)(ii) in reverse. In your scenario using 1.33 SG, 4 one-gallon containers plus the tare weight of 3 pounds, the packaging may be certified to 23.1 kg. This is calculated by taking the rated capacity of the packaging in liters (4 gallons = 15.14 liters) times the specific gravity (1.33 as calculated above) to get the maximum gross weight in kilograms [§ 173.24(b)(3)]. We note that this calculation does not leave any margin for error; the package failed at an incremental increase in drop height. Since each packaging must be capable of passing all the performance tests at any time during transportation, we recommend that you reduce the authorized specific gravity some reasonable amount so as to provide a greater margin for variation in performance of the production packagings. 8.403 010115#

Page 2.. • Q2. May the maximum gross weight of a packaging be marked to 1 decimal place or must it be a whole number rounded down? A. The maximum gross weight for a packaging may appear as a whole number rounded down or may appear rounded to the first decimal. Q3. May the specific gravity be marked on a packaging to 2 decimal places? How should it be rounded? Should the actual SG be used to determine drop height or the rounded down SG? A. As provided by § 178.503(a)(4)(i), single packagings intended to contain liquid are marked with the specific gravity rounded down to the first decimal and may be omitted when the specific gravity does not exceed 1.2. The actual SG should be used to determine drop height. I hope this information is helpful. Sincerely, Director, Office of Hazardous Materials Standards#

Page 3gh Package Jgh & Product Fairfield, OH 45014 325 Commercial Dr. Phone (513) 870-0080 Fax (513) 870-0017 Testing and Consulting, Inc. 335 W. Melinda Lane Phoenix, AZ 85027 Phone (623) 869-8008 Fax (623) 869-8003 May 3, 2001 Edmonson To: Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards $ 172.312 U.S. DOT/RSPA (DHM-10) 400 7th Street S.W. Washington, DC 20590-0001 3118.603 From: Mr. H. Perry Hock Marking + Testing gh Package & Product Testing and Company Technical Director 01-0115 Subject: Non-bulk performance-oriented packaging. Dear Mr. Mazzullo, I have several questions regarding marking and the testing of non-bulk packagings. The pack consists of 4 plastic one-gallon jugs filled with windshield wiper fluid. The client approach to determine the highest SG allowed to be placed in it? E.G. The packs pass at 53 inches but not 54. Since 53 is less than group I but more than group II, We would use the group Il formula: SG x 3.3 feet (39.6 inches) = 4.416 feet (53 we can then rewrite the formula: SG = 4.416 Feet 3.3 Feet SG = 1.33 Now using 1.33 SG, and the packaging consists of 4, 1-gallon containers, and the tare weight pfile packaging is 3lbs, what would be the appropriale weight to be marker on the 40 1.33 × 8.43 (weight of one gallon of water) = 11.21 Ibs. per bottle 4 bottles x 11.21 Ibs. = 44.84 Ibs. just for the contents 44.84 Ibs. + 3 1bs. of packaging = 47.84 Ibs. (21.7 kg) Ed Mazzullo Letter 5-3-01#

Page 4Page 2 Question 2: ind testing of non-bulk pack Question 3 May the specific gravity of the material be marked on the pack to 2 decimal places? If the SG cannot be marked to two decimal places, how should it be rounded? How should it be tested rounded SG? and to what drop height? Should the actual SG be used for the drop height or the new, This question may seem like it does not have merit until you consider the impact it has on should be marked on the drum? If it is to be marked to a single decimal rounded down, the shipper can loose more than 4 gallons per drum. Question 4 The elient submits a pack of 4 metal 1-gallon containers that are filled with water. Water's SG is 1.0. The SG of the product they want to put inside of the pack is 1.18. Both fall under product. What drop height should be used to compensate for the weight difference? If the the 1.2 cutoff to use, but the tested pack weighs 5.4 Ibs. less than the package with the actual tested. If the drop height is altered to a higher drop height, then the pack can be marked drop height is not altered, then theoretically the pack must be marked with the weight same with the appropriate ship weight - which would be 2.4 kg higher. Similar scenario: party test lab that their 4G pack will weigh no more than 24 Ibs. when shipped. When we A client has a 4G combination pack with plastic inners for liquids. They tell us, the third receive the samples filled with wiperfluid, the packs weigh 18 Ibs. What is the correct way of determining the drop height for this pack? Can a ratio be used? would be 48 inches. Example: shipped weight is 40 Ibs. but the tested weight is 36 Ibs. The drop height for 40 Ibs.#

Page 5- .:: Page 3 The ratio would be: Product Ship Weight New Drop Height Test Pack Weight Required Drop Height And then rewritten as: Product Ship Weight × Required Drop Height Test Pack Weight = New Drop Height 40Ibs.x 48 Inches 36lbs. - = 53.3 Inches I realize the drop height can never be lower than the required drop height but would this be acceptable for determining a pack's drop height when no specific gravity is given? 7 letter, please call me at 513.870.0080 I look forward to your response: If you need clarification or have questions regarding this Yours Truly, H. Perry Hock Technical Director gh Package & Product Testing and Consulting, Inc. HPH/hph#