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

Page 1U.S. Department Research and of Transportation APR 30 2003 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Administration Technical Director Mr. H. Perry Hock Ref. No. 02-0283 gh Package & Product Testing 325 Commercial Drive and Consulting, Inc. Fairfield, OH 45014 Dear Mr. Hock: ! This responds to your letter regarding the performance testing of UN standard packagings under the Hazardous Materials Regulations the drop test height for a drum intended for a solid, may be (HMR; 49 CER Parts 171-180). Specifically, you inquire whether adjusted as if it were a liquid with a specific gravity greater apologize for the delay in responding. than 1.2, using the formula specified in $ 178.603 (e) (2) (ii). tested with either the hazardous material to be transported or a non-hazardous material having essentially the same physical $ 178.603 (e) (1) . characteristic according to the drop heights specified in authorizing a different test method than those prescribed under You may, however, apply for an approval $ 178.601 (h). The specified in § 107.705. procedures for applying for an approval are I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hothe z mitchell Hattie I. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 178.603 020283#

Page 2Oct-24-02 08:32A gh testing 513 870 0080 P.02 gh Package /gh & Product 3a6 Concis Di Phone (513) 870-008 ax (513) B70-001 Testing and o Consulting, Inc. 335 W. Melinda Lane Phoenix, AZ 85027 hone (623) 869-800 ax (623) 869-800 Stevens May 28, 2002 § 173.24 a (b)E) To: Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards § 178.603 U.S. DOT/RSPA (DHM-10) 400 7ch Street S.W Washington, DC 20590-000 Testing 02-0283 From: Mr. H. Perry Hock Technical Director gh Package/Product Testing and Consulting, Inc Fairfield, OH 45014 325 Commercial Dr. Subject: Non - Bulk Single pack testing pursuant to CFR 49, § 173.24a (b)(3) and §178.603 Dear Mr. Mazzullo, 1 have a question regarding CFR 49, §173.24a (b)(3) and §178.603 for non-bulk single packs. solid hazardous material. Using sand, lead and steel, we are capable of only achieving 250 Scenario - We have a 30 gallon drum to be filled to a maximum gross weight of 300 kg of allows the drop height for liquids to become the specific gravity multiplied by the group level. "g. Why can the drop height not be raised as if it were for liquide? I ask this since §178.603 Another way to look at this scenario might be to the heights determined using §178.603 (e)(2)(ii)? The specific gravity of the solid being placed in the 30 gallon drum equals 2.6. Can you use If you cannot use the heights determined using 5178.603 (e)(2)(ii), why? I ask because it would be contradictory to not allow this use since the drum could be tested with water and the drop height be calculated based on $178.603 (e)(2)(ii), and then apply exceeding the rated capacity of the packaging in liters, multiplied by the specific gravity §173.24a (b)(3) - A packaging tested for a liquid can carry a solid to a gross mass not marked on the packaging. I look forward to your response. If you need clarification or have questions regarding this letter, please call me at 513.870.0080 Yours Truly, Technical Director Perry Hock gh Package & Product Testing and Consulting, Inc. HPH/Aph Ed Mazzullo Letter 5-28-02.doc#