Wyle Laboratories — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1 200 New Jersey Ave, SE Pipeline and Hazardous Materials Washington, D.C. 20590 Safety Administration OCT 1 2 2011 Mr. Brian Coppock Manager, Product SafetylPackaging Technology Wyle Laboratories 7800 Highway 20 West Huntsville, AL. 35806 Reference No. 11-0200 Dear Mr. Coppock: This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to wooden large packagings. SpecificalJy, you ask for us to clarify which evaluation criteria would be used in the stacking test with a large wooden packaging using static weights. You state that § I 78.980(e) "Criterion for Passing the Test" addresses specific categories of large packagings, but that there is no reference for the criterion for a wooden large packaging undergoing a static weight test. This appears to be an oversight and we are evaluating this issue to determine the need for a rulemaking. In the meantime, we recommend the criteria provided in § 178.980(e)(1). Also, in the HM -231, "Miscellanous Packaging Amendments," final rule that was published on September 30,2010 (75 FR 60333), we stated that the design, construction and testing requirements are based on the UN Recommendations on the Transport of Dangerous Goods, Thirteenth Revised Edition (2003); Chapter 6.6, Requirements for the Construction and Testing of Large Packagings. Section 6.6.5.3.3.5 provides the criteria for passing the stacking test for large packagings as, "No pe~manent deformation which renders the large packaging unsafe for transport and no loss of contents," to cover all of the large packaging construction types. I hope this information is helpful. Please contact this office should you need additional assistance. Sincerely, r-7~?L~ T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Drakeford. Carolyn (PHMSA) From: INFOCNTR (PHMSA) /1- OZOO Sent: Tuesday, August 16, 2011 4:23 PM To: Drakeford, Carolyn (PHMSA) Subject: FW: Request for Official Letter of Interpretation Attachments: image001.jpg; image002.gif We received the following request for a letter of interpretation at the I nfo Center. The caller previously spoke with Vince Hi Carolyn, Babich. Thanks, Victoria Victoria Lehman Hazmat Information Center (HMIC) http://phmsa.dot.gov/hazmat/info-center (202) 366-1035 From: Coppock, Brian [mailto:Brian.Coppock@wyle.com] Sent: Tuesday, August 16, 2011 11:47 AM To: INFOCNTR (PHMSA) Cc: Hardy, Bobby; Bates, Dawn; Fisher, Ronda Subject: Request for Official Letter of Interpretation Dear Sir/Madam, I am writing to request an interpretation of 49 CFR Part 178 Subpart Q IITesting of Large Packagings", specifically 178.980(e) "Criterion for Passing the Test" for the Stacking Test. The subject section appears to address specific categories of Large Packagings but I do not find a reference for the criterion for a wooden Large Packaging undergoing a static weight test. If you could, please clarify what evaluation criteria would be used in the event of an anomaly in the stacking test with a wooden Large Packaging using static weights. Thank you, Brian Brian Coppock Manager, Product Safety/Packaging Technology ••rctle ·WVJ~ 7800 Highway 20 West Huntsville, AL. 35806 V.(256) 716-4270 F.(256) 721-0144 Brian.coppock@wyle.com http://www.wyle.com 1#

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