{"operation":"document","citation":"13-0091","title":"Gh Package/Product Testing and Consulting, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-07-31","effective_on":null,"summary":"13-0091 response to Gh Package/Product Testing and Consulting, Inc. concerning 178.516, 178.603.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0091.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0091.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-13-0091","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130091.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nJUL 3 1 2013\nMr. Ronald .T. Sorrell\nGh Package/Product Testing and Consulting, Inc.\n4090 Thunderbird Lane\nFairfield, OH 45014\nRefNo.: 13-0091\nDear Mr. Sorrell:\nThis is a response to your April 30, 2013 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 1 00-185) with regard to the assembly of a UN 4G\nfiberboard box. Specifically, you seek clarification on the criteria for passing the drop test\nspecified in§ 178.603.\nIn your incoming email you describe a telescoping box with a loaded base and a top that\nslides over the base. The box is assembled both with and without a band or tape around the\ngirth of the closed packaging. This packaging has been tested in accordance with the design\nqualification testing specified in Part 178 Subpart M and in both configurations successfully\npassed all required tests, including the drop test in§ 178.603. However, for the assembled\nbox not secured by a band or tape around the girth, you observe that after the drop test, the top\nportion of the telescoping box is raised 2-3 inches with no release of product. You question\nwhether the raised lid after the drop test constitutes a closed packaging.\nThe answer is yes. Provided there is no release of contents from the packaging and the\npackaging passes all applicable UN Specification tests, this would be permissible. It should\nbe noted that the standards for fiberboard boxes in § 178.516(b )(5) require that boxes must be\ndesigned so as to provide a snug fit to the contents. The drop test described above may be an\nindication that the assembled box not secured by a band or tape around the girth does not meet\nthe intent of§ 178.516(b)(5).\n1 hope this information is helpful. If you have any more questions, please do not hesitate to\ncontact this office.\nSincerely,\nRobert Benedict\nChief, Standards Development\nStandards and Rulemaking Division\n\n<<>>\n\n• Sec.vre...\\1 do~J ?\n. gd ~IJ.Se_ I ',f t>Jll~\n\"lest-re~(\n·rrB, Sl6(6)Cs-)\n? ) 7-:J_ 2'1 (I) (1)(i i)\n--\n------\n----\n--·---------\n\n<<>>\n\nDrakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nSubject: Lima, Anthony (PHMSA)\nTuesday, April 30, 2013 9:40AM\n13- OOCf I\nDrakeford, Carolyn (PHMSA)\nRequest for Clarification from gh Package I Product Testing and Consulting, Inc.\nCarolyn,\nPlease log Ron Sorrell's question below as a request for written clarification. Ben Moore thinks it's best to hash\nthis issue out.\nThanks\nAnthony Lima\nPackaging Program Manager/Senior Investigator\nOffice Of Hazardous Materials Safety\nField Operations\nU.S. DOT/PHMSA\n(856) 265-3054 (mobile)\n(302) 336-9693 (e-fax)\nanthony.lima@dot.gov\nwebsite: hazmat.dot.gov\nFrom: Moore, Benjamin (PHMSA)\nSent: Tuesday, April 30, 2013 9:32 AM\nTo: Lima, Anthony (PHMSA)\nCc: Ron Sorrell\nSubject: RE: Telescoping box closure\nAnthony and Ron,\nI can't find anything that might cover this other than 178.516(b)(S) which states \"Boxes must be designed so as to provide\na snug fit to the contents,\" which it doesn't sound like it's really doing except that it's only occurring during a test. I would\nsay a clarification from Standards might not be a bad idea, since I have a hard time saying this is not complying with the\nHMR.\nBenjamin Moore\nGeneral Engineer\nOffice of Hazardous Materials Technology\nPHONE: (202) 366-4545\nFAX: (202) 366-3650\nFrom: Lima, Anthony (PHMSA)\nSent: Tuesday, April 30, 2013 9:21 AM\nTo: Moore, Benjamin (PHMSA)\nCc: Ron Sorrell\nSubject: RE: Telescoping box closure\nBen,\n1\n\n<<>>\n\nRon's question below is probably best answered by other than field ops. If you think this should be handled as a\nrequest for clarification, we can forward the email to Standards instead. Please advise.\nThanks\nAnthony Lima\nPackaging Program Manager/Senior Investigator\nOffice Of Hazardous Materials Safety\nField Operations\nU.S. DOT/PHMSA\n(856) 265-3054 (mobile)\n(302) 336-9693 (e-fax)\nanthony.lima@dot.gov\nwebsite: hazmat.dot.gov\nFrom: Ron Sorrell [mailto:rsorrell@ghtesting.com]\nSent: Tuesday, April 30, 2013 9:18AM\nTo: Lima, Anthony (PHMSA)\nSubject: Telescoping box closure\nHello Mr. Lima\nI have a customer who uses a full telescoping box which ships hazmate material. He assembles the box with a loaded\nbase and then slides the top over the base. A band is put around the girth of the closed telescoping box as a security seal.\nIf not all the product is used, a piece of tape is put on the top and base to hold lid in place for return. We currently test the\ntelescoping box with the band and the tape and put both in the report.\nNow the customer wants to send the telescoping box with a load in it with no banding or tape at all. He does not want to\nuse anything for the closure besides the lid of the telescoping box. We tested the telescoping box without any bands or\ntape and the lid wants to raise 2\"-3\" up the base as a result from the drops. So my question is \"Does the lifting of the lid of\nthe telescoping box 2\"-3\" after drop considered closed or open\".\nBy the CFR 49 drop testing for non-bulk, the product is not exposed and the box is not ripped opened but what gets to me\nis the lid is a little less than half way up the base. Does this constitute a closed box?\nThank you for your time.\nftONALJ) J., SORR>>\n\nEmail:rsorrell@ghtesting.com 1 Website: www.ghtesting.com\nTesting Facility Service Offerings:\nDistribution (ASTM I ISTA) Testing 1 Environmental/ Thermal Testing 1 UN/DOT Testing I lATA 650 I Data Acquisition\nPackaged Products upto 8000 lbs.\n0'ista\n•:~e>mf!Hl LM'<:lW\\1'00'\\'\nThis electronic message transmission contains information from gh Package & Product Testing\nand Consulting, Inc. which may be confidential or privileged. The information is intended to\nbe for the use of the individual or entity named above. If you are not the intended recipient,\nbe aware that any disclosure, copying, distribution or use of the contents of this information\nis prohibited. If you have received this electronic transmission in error, please notify us by\ntelephone (1-513-870-0080) or by electronic mail (rsorrell@ghtesting.com) immediately.\n3","truncated":false,"body_characters":6369}