Alloy Products Corporation — Hazardous Materials Safety Interpretation

Page 1Washington, D.C. 20590 400 Seventh St., S.W. Research and special Programs dministratior DEC 4 3002 Mr. Peter El-Sabaaly Director of Engineering Ref. No. 02-0221 Alloy Products Corporation P.O. Box 529 Waukesha, WI 53187-0529 Dear Mr. El-Sabaaly: This responds to your August 16, 2002 letter requesting clarification on package testing requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the vibration standard under § 178.608 is required for the design qualification testing only and not the periodic retesting of packagings. Your understanding of vibration standard is that the vibration test is required for the design qualification testing only and does not apply to the periodic retesting. Your understanding is incorrect. All performance tests for design qualification testing and periodic retesting under §§ 178.603, 178.604, 178.605, 178.606, or 178.607, must be performed in accordance with provisions in § 178.601(c)(1) and (c)(2) at the frequency specified in 178.601(e). These performance tests are required to be performed and packages must successfully pass these tests before they can be certified as a UN performance packaging authorized to carry hazardous materials. However, as specified in § 178.608, each non-bulk packaging must be capable of withstanding, without rupture or leakage, the vibration test procedure outlined in this section. This capability can be demonstrated through the packaging performance history using this type of packaging or by performing the vibration test. The vibration test is not required to be performed for non-bulk packagings. For certain bulk packagings, such as intermediate bulk containers, the vibration test must be conducted for both design qualification and periodic retesting. I hope this answers your inquiry. Sincerely, See I thi Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 178.60| 020221 43008020#

Page 2Boothe ALLOY PRODUCTS CORP. $118.601 Stainless Steel Craftsmen Since 1929 desting, Waukesha, WI 53187-0529 P.O. Box 529 (414) 542-6603 Friday, August 16, 2002 Fax (414) 542-5421 Department of Transportation Office of Hazardous Material and Technology 400 7" Street Southwest Room # 8430 Washington, D.C., District of Columbia Reference: Bureau of Explosives, Tariff # BOE-6000 Attention : Mr. Thomas G. Allen Dear Mr. Allen Pring to de a guan ate tearing per Subin , a pril required i section Question: During periodic testing per section 178.601,6,2, are we required to perform the vibration test as well? My interpretation is that the vibration test is required for the design qualification testing only and it does not apply to the periodic testing. Am I correct? I am looking forward for your response. Thank you Regards, Peter Il. Jaborly Peter El-Sabaaly Director of Engineering DOT vibration.peter#