Ropak Packaging, West Division — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Hazardous Materials Safety VOV 25 2009 Administratior Mr. Terry Iker Reference No. 05-0095 Ropak Packaging, West Division Manager, Technical Services 14585 Industry Circle La Mirada, CA 90638 Dear Mr. Iker: This is in response to your letter asking for clarification of periodic packaging resting under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if non-bulk packagings selected at random by the manufacturer for periodic retesting must be less than one year old. The periodic retest requirements prescribed in § 178.601(c)(2), (e), and (f) do not specify the age of the non-bulk packagings to be tested. They are designed to serve as a quality control measure to ensure that all non-bulk, hazardous materials packagings manufactured since the last successful design qualification test or periodic retest, as applicable, are capable of meeting the appropriate UN performance standards. This can only be successfully demonstrated if the packagings sel cted for testing are those manufactured since the last successful performance test for that design by that manufacturer. Therefore, after the design qualification tests required under § 178.601(c)(1) are successfully completed for each new or different packaging at the start of production, subsequent productions of the approved packaging design must be periodically retested as prescribed in § 178.601(c)(2), (e), and (f). As stated in § 178.601(e), a single or composite packaging must be periodically retested once every 12 months, and a combination packaging must be periodically retested once every 24 months. We believe this testing frequency and method . e sufficient to ensure that all UN packagings are capable of passing the prescribed tests. Please note that a test report nust be completed for each packaging design qualification test and each periodic retes is prescribed in § 178.601(1) I hope this information is helpful. Sincerely, totte z. Mithel Hattie L. Mitchell, Chief Office of Hazardous Materials Standard: Regulatory Review and Reinventior 178.601 C)e)f) 050095#

Page 2LON Edmonson RA C Ropak Packaging Testring 14585 Industry Circle, La Mirada, California 90638 West Division 05-0095 Tel: (714) 522-6891 Fax: (714) 522-4531 ISO 9002 Certified Quality System March 10, 2005 U.S. DOT/PHMSA 400 7* Street S-W Office of Hazardous Materials Standards Washington DC, 20590 Attn: Mr. Edward Mazzullo were older than one year old. Section 178.601 (c), (e) and (f). Ref: Letter of Interpretation - Samples used for Periodic Retest of a single package, Dear Mr. Mazzullo Is there a requirement for random samples submitted for Periodic Retesting of a single package, to be of a certain age? e.g. samples must have been manufactured in the preceding year leading up to the renewal of the Periodic Retest. Section 178.601 (c), (e) and (f) does not appear to specify that random samples submitted for interval. However, there is a requirement that the subject samples must be capable of passing Periodic Retest must have been manufactured during the year of the most recent Periodic Retest the original design qualification tests. Please provide an "official" interpretation for my records on this issue. If you have any additional questions, please feel free to contact me at (714) 522-6891, xt 314. Sincerely Very kn Terry Iker Ropak Packaging Manager, Technical Services#