All-Pak Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E Washington, D.C. 20590 Mr. Christian Prickett All-Pak Inc. Corporate One West 1 195 Washington Pike Bridgeville, PA 150 1 7 Ref. No.: 09-0 19 1 Dear Mr. Prickett: This responds to your letter of August 19,2009, regarding testing of specification packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80). Specifically, you ask if your company may use another manufacturer's cap in place of the cap currently being used on the inner packagings of a combination packaging intended for the transportation of liquid hazardous materials. According to your letter, your company uses combination packagings consisting of four one- gallon plastic inner packagings placed inside of a UN 4G fiberboard box. The inner packagings were tested with a Van Blarcom 7.7 gram 38-CRC cap. You ask if you may substitute an alternative cap manufactured under the same process as the Van Blarcom cap - a Mold rite 38-CRC cap. The answer is yes. Section 178.601 (g) of the HMR provides a series of conditions for the selective testing of packagings that differ in only minor respects from a tested design-type (see 0 178.60 1 (g)(l)(i)(A)-(F)). In accordance with 9 178.60 1 (g)(l )(i)(C), you may vary the closures on inner packagings of a tested combination packaging without further testing of the package provided the inner packagings have the same or smaller openings as the tested design and the closure is of similar design as the tested design. The information provided with your letter indicates that the cap you wish to use is of the same design type as the cap used in the tested design; therefore you may substitute the Mold rite cap for the Van Blarcom cap. I hope this information is helpful. If we can be of further assistance, please contact us. Sinc ely, {JIQ) lp$#J Charles E. Betts Chief, Standards Development Office of Hazardous Materials Standards#

Page 2Page 1 of 1 Drakeford, Carolyn (PHMSA) --"-- - - -- --"-? -* - ------- - * "" From: INFOCNTR (PHMSA) Sent: Wednesday, August 19, 2009 3:31 PM To: Drakeford, Carolyn (PHMSA) Subject: FW: interpretation for 178.601 Attachments: BR 6425.pdf; CRC38 (Assembled).pdf From: Prickett, Christian T. [mailto:prickettc@alI-pak.com] Sent: Wednesday, August 19, 2009 1:24 PM To: INFOCNTR (PHMSA) Subject: interpretation for 178.601 Mr. Edward Mazzullo, We have a 1 gallon UN rated 4 pack tested with a Van Blarkum 7.7 gram 38-CRC cap. We have an alternative cap manufactured under the same process (injection molded unscrewing mold) that with the liner is about 7.8 to 8 grams (using the same thickness and type of lining material). I'd like to know, may I use the Mold rite 38-CRC with F217 liner as an LTN approved substation under the interpretation for 178.601 for substation in place of the Van Blarkum cap? I've found only one document on your website that discussed this but it talks about caps made of a different process and doesn't talk about matching specs at all. l?t.tu:!!w?vw.yh~.~~d.o_t'~.~.v!staticfiIesLP~~i.MMSs~!~eew_r!~oaCr.ableeE~!ees!fi'1!~s!I~~!~ xre ta t i0n%20E&e~!2002/@0126. pd! Information on the Mold Rite 38-CRC cap we are using can be found on the following link.. . !~.GP:~!YY w w.~~~lrp~~~~.~~~~!inf0/d.o~~ume~~t.s!.C.R.C38~r.~t_oc.~~.~~~.f The drawing of the cap is the PDF file CRC38 pdf attached. Please call me with any questions. Thank you, Christian Prickett All-Pak Inc. Corporate One West 11 95 Washington Pike Bridgeville, PA 150 17 Phone: (41 2) 257-3000 Fax: (412) 257-3001 Cell: (724)344-07 19 This message (including any attachments) is intended only for the use of the individual or entity to which it is addressed and may contain information that is non-public, proprietary, privileged, confidential, and exempt from disclosure under applicable law or may constitute as attorney work product. If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution, or copying of this communication is strictly prohibited. If you have received this communication in error, delete this message immediately. Thank you.#