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

Page 1• U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration JUL 1 0 2002 Mr. H. Perry Hock Ref. No. 02-0148 gh Package & Product Testing and Consulting, Inc. 325 Commercial Drive Fairfield, OH 45014 Dear Mr. Hock: This is in response to your May 26, 2002 letter concerning UN specification packaging testing under the Hazardous Materials Regulations (HMR; 49 CFR, parts 171-180). Specifically, you request clarification on the testing for UN 1A2 drum designed with and without a gasket between the lid and the drum. You ask if the six required drops for the drop test in § 178.603 could be performed on the drums and lids without the gasket, then perform three additional top diagonal drops on previously untested drums with the lids containing the gasket. You would then certify the drum as not having a gasket and the drum would also have an alternative closure with a gasket. Steel drums with and without a gasket would be considered to be different packagings under § 178.601(c)(4) and § 178.601(g)(8). Thus, you would have to perform separate drop tests on the two types of drums you wish to manufacture to UN specifications. In answer to your follow-up question asking if closed head drums having alternate bung caps could be tested in the way you proposed, if you meet the provisions of § 178.601(g)(5) (Variation 5), then only the requirements of that section need apply. If your change in bung caps does not meet the requirements under Variation 5 then that package would be considered a different packaging under § 178.601(c)(4) and § 178.601(g)(8) and would require the full drop test in order to be a UN Specification packaging. I hope this satisfies your request. Sincerely Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 2May: 20-02 03:21P gh testing 513 870 0080 P.02 "!? ... gh Package /gh & Product 22 or or rio Di Phone 513) 870-0080 Fax (513) 870-0017 Testing and o Consulting, Inc. 335 W. Melinda Lane Phoenix, AZ 85027 Fax (623) 869-8003 Phone (623) B69-8008 May 26, 2002 Johnsen To: Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards §178.603 U.S. DOT/RSPA (DHM-10) Washington, DC 20590-0001 400 7t Street S.W. Testino 12-018 From: Mr. H. Perry Hock Bh Package & Product Testing and Company Technical Director 325 Commercial Dr. Fairfield, OH 45014 Subject: Non - Bulk Single pack testing pursuant to CFR 49, § 178,603 - Drop Test Dear Mr. Mazzullo, I have a question regarding CFR 49, §178.603 for non-bulk single packs. The question pertades on type mily be tested. de druand be drope on tea is got chime al three drums to be dropped on the weakest part not previously tested by the first drop. The manufacturer wishes to have a 1A2 (open head steel drum) certified with and without a gasket between the lid and the drum. Can one perform the six required drops on the drums and lids without the gasket, and then containing the gasket? The drum would then be certified as not having a gasket and the perform three additional top diagonal drops on previoualy untested drums with the lids drum would also have an alternate closure with a gasket. This would save drum manufacturers great expense in not having redundant bottom or side drops since the drura itself has not changed. Along the same thought lines, would the same interpretation be made for closed head drums having alternate bung caps? I look forward to your response. If you need clarification or have questions regarding this letter, please call me at 513.870.0080 × 103 Youre Truly, gh Package & Product Testing and Consulting, Inc. Technical Director HPH/hph Ed Mazzulla Letter 5-20-02#