{"operation":"document","citation":"07-0125","title":"Dupont Automotive Systems — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-07-09","effective_on":null,"summary":"07-0125 response to Dupont Automotive Systems concerning 173.22.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0125.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0125.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0125","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070125.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\n1200 New Jersey Ave.. S.E.\nof Transportation\nWashington. DC 20590\nMaterials Safety\nPipeline and Hazardous\nAdministration\n2007\nMs. Randylynn Bourassa\nRef. No.: 07-0125\nDupont Automotive Systems\nMid America Distribution\nSafety Competency Lead\n400 Groesbeck Highway\nMount Clemens, MI 48043\nDear Ms. Bourassa:\nThis is in response to your May 31, 2007 letter regarding closure requirements for steel drums\nunder the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you\nask if you must remove and re-torque the head on open head steel drums you receive with the\nhead already installed and torqued by the supplier or manufacturer.\nThe answer is no. A manufacturer or supplier of performance-oriented packagings may provide\nempty drums to customers in any stage of assembly. Under § 178.2(c), the manufacturer or other\nperson certifying compliance with the requirements of Part 178, and each subsequent distributor\nof a packaging, must notify in writing each person to whom that packaging is transferred of all\nrequirements not met at the time of transfer (e.g., bung closure torque specifications). The\ninformation specified in the notification must specify the types) and dimensions of the closures,\nincluding gaskets and any other components needed to ensure that the packaging is capable of\nsuccessfully passing the applicable performance tests. It is the responsibility of the person filling\npackaging are closed in accordance with the written notification supplied by the manufacturer or\nand closing the drum to ensure that the closures not closed and torqued when they received the\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n178.2 (c)\n173.22\n070125\n\n<<<PAGE 2>>>\n\n490 Greesbeck Highway\nDuPont Automotive\nMount Clemens, Mi 48043\nOU POND®\nPollack\nDuPont Automotive\nMay 31, 2007\n'Responsibiliti\nEdward T. Mazzullo - Director\n01 - 0125\nOffice of Hazardous Materials Standards\nEast Bldg. 2nd Floor\nDOT/PHMSA Rm. PHH-10\nWashington, D.C. 20590\n1200 New Jersey Ave\nDear Mr. Mazzullo:\nI am writing in follow-up to a conversation with \"Rob\" at the PHMSA to request written\nconfirmation regarding the responsibility of drum closure where the closure is not altered by the\nshipper.\ndrums are filled from the small bung in the lid of the drum. 1A2 drums are only used because of\nOur facility purchases both 1A1 and 1A2 steel 55-gallon drums for the shipping of Class 3 paint. All\ntreated at our facility as 1A1 drums). Our facility has the closure instructions and proper tools for the\ncustomer need, and the lids are not removed until the customer receives them (i.e. all drums are\nsmall bung that is opened and closed during the filling operation. Both closures are given inspection\nat the shipping dock as part of overall drum integrity inspection for damages, leakage, and obvious\ndesign non-conformances.\ntightening ring lugs per torque specifications, tightening lock nuts per torque specifications, and\nClosure for the 1A2 open head cover requires alignment of closing ring, insert of bolts and lock nuts,\nper specifications and \"ready for fill. This closure is not altered at the filling facility. On May 29,\n\"pounding\" of ring perimeter at specific location. We order the drums from our supplier \"tightened\"\nverbal confirmation that responsibility for closure of the lid remains with the container supplier as\n2007, I spoke with \"Rob\" at the PHMSA Hazardous Materials Information Center, and received\nmanufacturer instructions where the closure is not altered. If the shipper is responsible for this\npart of the container integrity, and that subsequent shippers are not required to apply closure per\nclosure, each lid would have to be removed (to inspect gasket and ring alignment), and re-torqued.\nIf I can answer any questions regarding this matter, please call the writer at (586) 468-9175. I look\nforward to your response.\nGarden Bannera\nE. I. DuPont de Nemours & Co.\nRandylynn Bourassa\nMid America Distribution Safety Competency Lead\nMt Clemens, MI 48043\n400 Groesbeck Hwy.\nE.t. du Por: de Nemours and Company\n* Printed on Recycied Paper","truncated":false,"body_characters":4275}