{"operation":"document","citation":"05-0204","title":"gh Package & Product Testing — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-08-24","effective_on":null,"summary":"05-0204 response to gh Package & Product Testing concerning 178.606.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0204.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0204.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0204","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050204.pdf","body":"<<<PAGE 1>>>\n\nWashington, D.C. 20590\n400 Seventh Street, S.W.\nPipeline and\nHazardous Materials Safety\nAdministration\nAUG 24 2006\nPresident and Technical Director\nMr. H. Perry Hock\nRef. No.: 05-0204\ngh Package & Product Testing\n4090 Thunderbird Lane\nConsulting, Inc.\nFairfield, OH 45014\nDear Mr. Hock:\nThis responds to your letter requesting clarification of the Hazardous Materials\nlegulations (HMR; 49 CFR Parts 171-180) pertaining to the stack test prescribed i\ntest, and how a guided load stack test should be set up and performed. You enclosed\n178.606. Specifically, you asked when is it permissible to use a \"guided load\" stac\nillustrations and photographs of the tests.\nYou provided a scenario as follows:\ndead load on each individual packaging or container, the packaging may fail. Frequently,\nWhen the gh Testing laboratory performs an \"unguided\" stack test, using steel plates as\nthe failure results in one side of the specimen collapsing and not being able to keep the\nweight centered above it; however, the packaging remains intact without rupture or loss\nstill intact and no loss of contents has occurred. You asked the following questions:\nof contents. Several of your clients assert that this is not a failure since the packaging is\nQ1. Is my client correct that this is not a failure of the stack test since the packaging is\nstill intact and no loss of contents has occurred?\nIn a guided load stack test, a load is directed vertically onto the test sample and\napplica. The aparasifin in your ofustrions may be use do cohave to be\nstacking test prescribed in $ 178.606, provided a constant load is applied for the\nНІНИННІ\n050204\n178.606\n\n<<<PAGE 2>>>\n\n24-hour duration of the test. If this equipment is used, a stack stability assessment\nmust be made for one hour at the conclusion of the test.\nThe stacking test is conducted to ensure that the inner receptacles or inner\npackagings do not leak any of the contents. The stability test ensures that the\nstacked packages are stable during transportation. There must be no leakage of\nthe filling substance from the inner receptacle or inner packaging. No test sample\nany distortion likely to reduce its strength, cause instability in stacks of packages,\nmay show any deterioration which could adversely affect transportation safety or\nor cause damage to inner packagings likely to reduce safety in transportation.\nThus, the scenario you describe constitutes a failure of the packaging to pass the\nprescribed test.\nQ2.\nWhen a gh Testing laboratory places three of the same, unmodified \"packs\" into\ntest that follows, are the packs considered to have passed the test?\nthe guided load stack test fixtures, and they pass the test, as well as the stability\nA2.\nThe answer is yes.\nQ3.\nAre the two tests supposed to give the same results?\nA3.\nIt's our expectation that the two stack tests (guided or unguided load) give the\nsame or similar results.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us.\nSincerely,\n7\nJohn A. Gale\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\ngh Package\n& Product\nairfield, OH 45014\n090 Thunderbird Lane\nPhone (513) 870-0080\nFax (513) 870-0017\nTesting and\nConsulting, Inc.\n335 W. Melinda Lane\nPhoenix. AZ 85027\nPhone (623) 869-8008\nFax (623) 869-8003\nAugust 1, 2005\nEngruno\nTo:\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\n6178.606\n4007' Street S.W.\nU.S. DOT/RSPA (DHM-10)\nlesting\nWashington, DC 20590-0001\n05-0204\nFrom: Mr. H. Perry Hock\nPresident and Technical Director\ngh Package & Product Testing and Company\n4090 Thunderbird Lane\nFairfield, OH 45014\nSubject: Performance testing of non-bulk packagings pursuant to CFR 49, §178.606\nDear Mr. Mazzullo,\n$178.606. Specifically when it is permissible to use a guided load stack test, and how a\nI am in need of a clarification on the regulations pertaining to the stack test as detailed in\nguided load stack test should be set up and performed.\nThis question has been arising more often, as companies try to reduce cost by minimizing\npackaging remains intact without rupture or loss of contents. Once this happens, the\nweight falls.\nA debate has begun over the regulations and their intentions. An interpretation most\noften given to gh Testing, from several of our clients, claims that this is not a failure since\nthe packaging is still intact and no loss of contents has occurred. Is our client correct\nwith their interpretation of the regulations since the pack did not rupture or lose contents?\nThe debate is that the stack test is to ensure the pack does not rupture under the load - not\nthat it is a stability test. The debate then continues that the stability portion of the testing\nis ensured via the hour long stability test following the stack portion of the test.\nWhen gh Testing places three of the same, unmodified, packs into the guided load stack\ntest fixtures, they pass the test, as well as the stability test that follows. Are the pack\nconsidered to pass the test? What if the pack was never tested using the unguided method\nresults?\nand only resulted in the passing of the test? Are the two tests supposed to give the same\n\n<<<PAGE 4>>>\n\nI have seen illustrations and pictures from other institutions on how they perform a\nguided load stack test. I would like to know which is permissible pursuant to the\nregulations.\nload fixture, each with the required weight above it. Following this test, the stability is\nThe first illustration is where all three required packs are placed into the sarne guided\nassessed pursuant to the regulations.\nEach stack 600 lbs.\n(1800 Ibs. total)\nany load and is not meant to be stacked on as a single unit. A good example might be a 5\nI can understand performing the testing in this manor if the pack by itself car not balance\ngallon bottle with a tapered neck.\nThe second illustration is one where an additional pack is \"tested\", using the guided load\nmethod as above. This is done since three packs cannot fit into or under the guided load\nfixture. Again, the stability would be assessed following the required stack test period.\n- so seat on calculation\n(2400 Ibs. total)\n-Extra Pack\n\n<<<PAGE 5>>>\n\nThe third illustration is one where each pack is tested individually in a guided load stack\ntest fixture. Again, the stability would be assessed following the required stack test\nperiod.\n- Each stack 600 Ibs.\nTUTT\nTOT\nAnd the fourth illustration is an unguided load stack test.\n- Each stack 600 Ibs.\n\n<<<PAGE 6>>>\n\nBelow are photos of actual testing conducted at gh Testing.\nResults of unguided load test - pack was unable to maintain the load of 583 Ibs. and the\npack collapsed.\nGuided Load Stack - with 17 additional pounds per pack for a total of 600 Ibs. per stack:\nStart of the test - the packs are supporting the entire weight, and the load spreader\n(plywood) is not touching any of the safety guides.\n\n<<<PAGE 7>>>\n\nAfter 24 hours, the load has shifted to the back side of the packagings, and the load\nspreader is now touching both the far and near guides.\nSingle pack, 104°, after 28 days\nCombination pack, after 24 hours\nNote the \"uniform crush\". We typically see the same results whether a single pack is\nused in a guided load, or all three are placed in a straight line across, such as the photo\ntypically see same results as above. The packs tend to perform better in the triangular\nabove. The exception is when the packs are staggered in a triangular pattern, we do not\nstack test pattern since the weight shift seen above is very unlikely to occur in a staggered\nstack.\n\n<<<PAGE 8>>>\n\nStability test on the above packs (only photos of two stacks of the single unit and one\nstack of the combination pack are included, but all six stacks passed):\nStability tests after one hour\nIf you have any further questions, please do not hesitate to call me at 513.870.0080 x 103.\nI look forward to your prompt response.\nYours Truly,\nPresident and Technical Director\nH. Perry Hock\ngh Package & Product Testing and Consulting, Inc.","truncated":false,"body_characters":8019}