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

Page 1of Transportation U.s. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration MAR 24 2004 Mr. H. Perry Hock gh Package & Product Testing Ref. No. 02-0232 325 Commercial Dr. and Consulting, Inc. Fairfield, OH 45014 Dear Mx. Hock: This is in response to your letter requesting clarification of che requirements of the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180) regarding the marking and testing of a combination packaging. Your questions are paraphrased and answered below. Q1. fiberboard box and an inner metal can with a gross mass of 7.3 One combination packaging consists of an outer 4G kg. outer 4G fiberboard box and an inner glass bottle with a gross Another combination packaging consists of an identical mass of 5.3 kg. gross mass tested, or must the packaging be dual marked with May the packagings be marked with the highest both the higher and the lower gross weights? AI. For a packaging accordance with § 178.503 (a) (3), it is not appropriate to mark containing the inner glass packaging, in tested. the packaging to a higher gross The packagings may be marked with both specification weight than for which it was markings. However, unless the non-applicable marking is could result in a violation of the regulations. The conditions covered or obliterated, the dual marks may cause confusion and for use would have to be clearly set forth in the notification to users required by § 178.2 (c). 22. gravity of the liquid is unknown, may we use the formula "PG When testing a combination packaging and the specific adjusted drop height," drop height X desired gross mass : actual package gross mass = the packaging, to determine the adjusted drop height under which is based on the desired gross mass § 178.603 (e) (2) (1i)? A2. The formula you presented in your letter is not in accordance with the formula provided in § 178.603 (e) (2) (ii) of :.:. 020232 178.503, 178.602#

Page 2in your the HMR. Based upon the formula and the information provided calculated without knowing the maximum specific gravity of the letter the minimum acceptable drop height can be product that will be packaged. § 178.603 (e) (2) (ii) is as follows: from the revised drop height calculations presented in The correct formula derived H = (M-I) X D/W H Where M = Drop height Certified gross mass = Tare weight of packaging W Variable for correcting Packing Group (1.5, 1.0 or -67 meters) = Weight of water in kg or Volume of water in liters correct calculation is: Using the example from your letter (after H converting to kg) the T M = Drop height W D = 0.7 kg 6.4 kg = 3.8 liters or kg 1.0 for Packing Group II 1.5 meters (6.4-0.7) X 1.0/3.8 = Your formula provides for a drop height of: H = 1.7 meters 1.2 X 6.4/4.5 = If in all cases your formula provides greater than the minimum required by the HMR, it is acceptable for a height that is the minimum requirements for testing a package. to use the greater height for package testing as the HMR provide I hope this information is helpful. questions, please contact this office. If you have additional Sincerely, Htotle.X. Mitchell Chief, Hattie L. Mitchell Office of Hazardous Materials Standards Regulatory Review and Reinvention#

Page 3Sep-10-02 09:36A gh test1ng 513 870 0080 P.02 gh Package gh & Product Fairfield, OH 45014 325 Commercial Dr. Phone (513) 870-0080 Fax (513) 870-0017 Testing and Consuiting, inc. Phoenix, AZ 85027 335 W. Melinda Lane Fax (623) 869-8003 Phone (623) 869-8008 McIntyre September 10, 2002 $178.503 To: Mr. Edward T. Mazzullo U.S. DOT/RSPA (DHM-10) Director, Office of Hazardous Materials Standards 3178.602. Washington, DC 20590-0001 400 7b Street S.W. Marting Tiesting From: Mr. H. Perry Hock Technical Director gh Package & Product Testing and Consulting, Inc. 02-0232 Subject: Marking and testing of Non-bulk performance-oriented packaging. Dear Mr. Mazzullo, I have several questions regarding the marking and testing of non-bulk packagings. he customer also packs in that 4G box an amber glass bottle with a screw cap that holds llon of a group I material. The maximum weight that the shipper places in the glass par is 5.3 kg. UN///73? My second question is about the drop test and combination packs. Currently, to determine the drop height on a combination pack filled with water or anti- he drop height based on the specific gravity, could a mathematical equivalent be used basec reeze, one must know the specific gravity of the material of landing. Instead of determining on the marked gross mass? Using a ratio, you can determine the drop height based on the marked pross mass of the combination pack Group Level Drop Height × Desired Pack Weight = Adjusted Drop Height × Actual Pack Weight Or re-written as: GroupLevelDropHeight x DesiredPackWeight ActuaiPackWeight " = AdjustedDropHeight Ed Mazzullo Letter 9-10-02.doc#

Page 4Sep-10-02 09: 36A gh testing 513 870 0080 P.03 Page 2 of 2 ravity of the lading, but the pack weight as wel his actually yields a higher drop height since this not only takes into account the specif Example: You have 1 gallon of a substance that is group Il and the substance has a SG of 1.5, and the ackaging materials weigh 1.6 Ibs. The desired gross mass of the pack is 6.4 kg. The actua ross mass of the pack filled with water is 4.51 ke Using $178.603 (e)(2)(ii), the drop height is 1.5 X 3.3 feet = 4.95 feet Using the ratio, the drop height would be: GrouptevelDropHeight(3.9 feet)x DesiredPackWeight(64kg) = AdjustedDropHeight ActualPackWeight (4.51) 5.53 feet = AdjustedDropHeight Allowing the use of the ratio wonld allow ua ms a testing facility to perform or tasks with 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#