{"operation":"document","citation":"02-0148","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":"2002-07-10","effective_on":null,"summary":"02-0148 response to gh Package & Product Testing and Consulting, Inc. concerning 178.603.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0148.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0148.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0148","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020148.pdf","body":"<<<PAGE 1>>>\n\n•\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nJUL 1 0 2002\nMr. H. Perry Hock\nRef. No. 02-0148\ngh Package & Product Testing and Consulting, Inc.\n325 Commercial Drive\nFairfield, OH 45014\nDear Mr. Hock:\nThis is in response to your May 26, 2002 letter concerning UN specification packaging testing under\nthe Hazardous Materials Regulations (HMR; 49 CFR, parts 171-180). Specifically, you request\nclarification on the testing for UN 1A2 drum designed with and without a gasket between the lid and\nthe drum. You ask if the six required drops for the drop test in § 178.603 could be performed on the\ndrums and lids without the gasket, then perform three additional top diagonal drops on previously\nuntested drums with the lids containing the gasket. You would then certify the drum as not having a\ngasket and the drum would also have an alternative closure with a gasket.\nSteel drums with and without a gasket would be considered to be different packagings under\n§ 178.601(c)(4) and § 178.601(g)(8). Thus, you would have to perform separate drop tests on the\ntwo types of drums you wish to manufacture to UN specifications. In answer to your follow-up\nquestion asking if closed head drums having alternate bung caps could be tested in the way you\nproposed, if you meet the provisions of § 178.601(g)(5) (Variation 5), then only the requirements of\nthat section need apply. If your change in bung caps does not meet the requirements under Variation 5\nthen that package would be considered a different packaging under § 178.601(c)(4) and\n§ 178.601(g)(8) and would require the full drop test in order to be a UN Specification packaging.\nI hope this satisfies your request.\nSincerely\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nMay: 20-02 03:21P gh testing\n513 870 0080\nP.02\n\"!?\n...\ngh Package\n/gh\n& Product\n22 or or rio Di\nPhone 513) 870-0080\nFax (513) 870-0017\nTesting and\no Consulting, Inc.\n335 W. Melinda Lane\nPhoenix, AZ 85027\nFax (623) 869-8003\nPhone (623) B69-8008\nMay 26, 2002\nJohnsen\nTo:\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\n§178.603\nU.S. DOT/RSPA (DHM-10)\nWashington, DC 20590-0001\n400 7t Street S.W.\nTestino\n12-018\nFrom: Mr. H. Perry Hock\nBh Package & Product Testing and Company\nTechnical Director\n325 Commercial Dr.\nFairfield, OH 45014\nSubject: Non - Bulk Single pack testing pursuant to CFR 49, § 178,603 - Drop Test\nDear Mr. Mazzullo,\nI have a question regarding CFR 49, §178.603 for non-bulk single packs. The question\npertades on type mily be tested. de druand be drope on tea is got chime al\nthree drums to be dropped on the weakest part not previously tested by the first drop.\nThe manufacturer wishes to have a 1A2 (open head steel drum) certified with and without a\ngasket between the lid and the drum.\nCan one perform the six required drops on the drums and lids without the gasket, and then\ncontaining the gasket? The drum would then be certified as not having a gasket and the\nperform three additional top diagonal drops on previoualy untested drums with the lids\ndrum would also have an alternate closure with a gasket.\nThis would save drum manufacturers great expense in not having redundant bottom or side\ndrops since the drura itself has not changed.\nAlong the same thought lines, would the same interpretation be made for closed head drums\nhaving alternate bung caps?\nI look forward to your response. If you need clarification or have questions regarding this\nletter, please call me at 513.870.0080 × 103\nYoure Truly,\ngh Package & Product Testing and Consulting, Inc.\nTechnical Director\nHPH/hph\nEd Mazzulla Letter 5-20-02","truncated":false,"body_characters":3728}