{"operation":"document","citation":"13-0030","title":"3737 Miller Park Drive — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-03-25","effective_on":null,"summary":"13-0030 response to 3737 Miller Park Drive concerning 173.24.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0030.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0030.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0030","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130030.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nM~R 2 5 Z013\nMr. Harold DePriest\nBway Corporation\n3 73 7 Miller Park Drive\nGarland, TX 75042\nRef. No.: 13-0030\nDear Mr. DePriest:\nThis is in response to your January 25, 2013 email and conversation with a member of my\nstaff requesting clarification of the performance-oriented packaging testing requirements in\naccordance with Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You\ndescribe a scenario where you have two pails of the same diameter, but different heights that\nwill be joined together for sales purposes via the use of plastic clips. You seek clarification\nregarding the testing and marking requirements for the joined unit. Specifically, you ask\nwhether performance-oriented packaging testing is required on only the individual pails or\non the entire joined unit.\nSection 178.601(a) states that the test procedures described in Subpart Mare intended to\nensure that packages containing hazardous materials can withstand normal conditions of\ntransportation and are considered minimum requirements. Each packaging must be\nmanufactured and assembled so as to be capable of successfully passing the prescribed tests\nand of conforming to the requirements of § 173 .24 of this subchapter at all times while in\ntransportation.\nBased on the scenario described, each design type (i.e. each pail) should be tested\nindividually in accordance with Part 178, Subpart M. In addition, each packaging that is\nrepresented as manufactured to meet a UN standard must be marked as specified in\n§ 178.503.\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\n02 - -\nDelmer~~\nSenior Regulato; ~Usor\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nlAI , e VJe r\"'\n§ 179. boO\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nINFOCNTR (PHMSA)\nMonday, January 28, 2013 12:53 PM\nDrakeford, Carolyn (PHMSA)\nFW: request for formal letter of interpretation\nHi Carolyn,\nWe received the following request for a formal letter of interpretation.\nThanks,\nVictoria\nFrom: Harold DePriest [mailto:Harold.Depriest@BWAYCorp.com]\nSent: Friday, January 25, 2013 11:57 AM\nTo: INFOCNTR (PHMSA)\nSubject: request for formal letter of interpretation\nI talked to Scott at the help desk today about an interpretation of 49CFR, paragraph 178.600 on testing for a new\npackaging. We have a customer who wants two individual pails of the same diameter, but different heights, joined\ntogether by plastic clips that makes it one sales unit. We asked how we would mark this packaging and how we would\ntest the unit. The initial response is that we would test each pail individually and mark them individually as separate\npackagings. These two packagings would not have an overall UN marking.\nI understand testing (leakproofness, hydrostatic, drop, stack and vibratory tests) and marking each container separately\nbut my question still concerns the two packagings that have been combined. Do we need to do any stack, drop or\nvibratory testing for the combined packaging?\nI need a formal letter of interpretation on the interpretation of paragraph 178.600.\nHarold DePriest\nBway Corporation\n3737 Miller Park Drive\nGarland, TX 75042\n972-535-1116\n972-535-1100 Fax\n1","truncated":false,"body_characters":3347}