Spartanburg Stainless Products, Inc — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Research and | Washington, D.C. 20590 pecial Program dministratio AUG 27 2002 Mr. Scott Rosenberger ›. O. Box 3488 Spartanburg Stainless Products, Inc Reference No.: 02-0164 Spartanburg, SC 29304 Dear Mr. Rosenberger: This is in response to your letter concerning marking UN specification drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your company manufactures Al steel drums trom two drawn shells. You state that during the manufacturing process, when the flat blank is drawn and stretched into a shell, the steel will thin in certain areas and thicken in others. You reference the "Die Makers Handbook" which states that thinning may be as much as 38% in the knuckle radius area. In your opinion, the tolerances found in ISO standard 3574 (see § 178.503(a)(9)) are too tight and do not appear to apply to drawn shells. Specifically, you ask if a greater tolerance is allowed how that should be reflected in the nominal thickness stamp. The HMR do not recognize the "Die Makers Handbook" you reference in your letter. Section 178.503(a)(9)(i) states that metal drums must be marked with the nominal thickness of the metal used in the body when the tolerance conforms to ISO Standard 3574. ISO 3574 dimensions define the nominal thicknesses and corresponding minimum thickness for steel sheets prior to subjecting the steel to any manufacturing processes, in your case drawing and stretching the sheets into shells used to form drums. The minimum thickness and nominal dimensions indicated in ISO 3574 are not applicable for steel sheets after forming operations, such as drawing and stretching the steel sheet into shells, are completed. The purpose of marking the drum with the ISO nominal thickness is to ensure safety in transportation by identifying the minimum permitted thickness of the drum, thereby indicating whether the drum is or is not suitable for reuse or reconditioning. Due to the unusual nature of your fabrication process, the drum should either be marked with the actual minimum thickness measured at the thinnest part of the drum or the ISO 3574 nominal thickness that corresponds to the measured minimum thickness. I hope you find this information helpful. If you have further question, please do not hesitate to contact this office. Sincerely, Edward T. Mazzullo Director, Office of Hazardous Materials Standards 178.503(9)19) 020164#

Page 2Corbin partanburg STAINLESS PRODUCTS INC. §178.503(9X1) Marking 02-0184 May 30, 2002 Research and Special Programs Administration Associate Administrator for Hazardous Material Safety 100 7" Street, SW, Washington, DC 20590-000 JS Department of Transportatior Attention: Standards DHM10 Dear Associate Administrator: I am witting to request a letter of interpretation on CFR 49 Section 178.505 (9) D. We manufacture 1A1 drums. Our vessel sub-assembly consists of two drawn shells. For a 15 Gallon thicknesses of materiai, depending on the design: 0.052", 0.059", and 0.079". As we all know, a flat drum, the shells would be approximately 15.5" Diameter by 10.5" draw depth. We start with several "Die Makers Handbook" by Jerry Arnold, it states that thinning can be as much as 38% in what we call blank, which is drawn and stretched into a shell, will thin in certain areas and thicken in others. In the the knuckle radius. The knuckle radius would be the transition between the top of the shell and the side. 178.503 (9)(i) discusses a tolerance, for the metal used in the body, found in ISO standard 3574. This too tight for drawn shells. If a greater tolerance is allowed than that of a flat blank, how should this be section does not seem to apply to drawn shells. The tolerances found in the ISO Standard 3574 are far reflected in our nominal thickness stamp? Sincerely, =35% 6.D322 inch scott Rosenberger Q.0aind Mech. Engr. Tech. Scott Rosenberger nomina! 0.7.2 173,28 A1.21 1036.:. Spartanburg, S.C. 29303 121 Broadcast Drive (888)974-7500 Mailing Address: P.O. Box 3488 (864)699-3200 Spartanburg, S.C. 29304 FAX (864)699-3250#