Gh Package/Product Testing and Consulting, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 JUL 3 1 2013 Mr. Ronald .T. Sorrell Gh Package/Product Testing and Consulting, Inc. 4090 Thunderbird Lane Fairfield, OH 45014 RefNo.: 13-0091 Dear Mr. Sorrell: This is a response to your April 30, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 1 00-185) with regard to the assembly of a UN 4G fiberboard box. Specifically, you seek clarification on the criteria for passing the drop test specified in§ 178.603. In your incoming email you describe a telescoping box with a loaded base and a top that slides over the base. The box is assembled both with and without a band or tape around the girth of the closed packaging. This packaging has been tested in accordance with the design qualification testing specified in Part 178 Subpart M and in both configurations successfully passed all required tests, including the drop test in§ 178.603. However, for the assembled box not secured by a band or tape around the girth, you observe that after the drop test, the top portion of the telescoping box is raised 2-3 inches with no release of product. You question whether the raised lid after the drop test constitutes a closed packaging. The answer is yes. Provided there is no release of contents from the packaging and the packaging passes all applicable UN Specification tests, this would be permissible. It should be noted that the standards for fiberboard boxes in § 178.516(b )(5) require that boxes must be designed so as to provide a snug fit to the contents. The drop test described above may be an indication that the assembled box not secured by a band or tape around the girth does not meet the intent of§ 178.516(b)(5). 1 hope this information is helpful. If you have any more questions, please do not hesitate to contact this office. Sincerely, Robert Benedict Chief, Standards Development Standards and Rulemaking Division#

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Page 3Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: Lima, Anthony (PHMSA) Tuesday, April 30, 2013 9:40AM 13- OOCf I Drakeford, Carolyn (PHMSA) Request for Clarification from gh Package I Product Testing and Consulting, Inc. Carolyn, Please log Ron Sorrell's question below as a request for written clarification. Ben Moore thinks it's best to hash this issue out. Thanks Anthony Lima Packaging Program Manager/Senior Investigator Office Of Hazardous Materials Safety Field Operations U.S. DOT/PHMSA (856) 265-3054 (mobile) (302) 336-9693 (e-fax) anthony.lima@dot.gov website: hazmat.dot.gov From: Moore, Benjamin (PHMSA) Sent: Tuesday, April 30, 2013 9:32 AM To: Lima, Anthony (PHMSA) Cc: Ron Sorrell Subject: RE: Telescoping box closure Anthony and Ron, I can't find anything that might cover this other than 178.516(b)(S) which states "Boxes must be designed so as to provide a 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 say a clarification from Standards might not be a bad idea, since I have a hard time saying this is not complying with the HMR. Benjamin Moore General Engineer Office of Hazardous Materials Technology PHONE: (202) 366-4545 FAX: (202) 366-3650 From: Lima, Anthony (PHMSA) Sent: Tuesday, April 30, 2013 9:21 AM To: Moore, Benjamin (PHMSA) Cc: Ron Sorrell Subject: RE: Telescoping box closure Ben, 1#

Page 4Ron's question below is probably best answered by other than field ops. If you think this should be handled as a request for clarification, we can forward the email to Standards instead. Please advise. Thanks Anthony Lima Packaging Program Manager/Senior Investigator Office Of Hazardous Materials Safety Field Operations U.S. DOT/PHMSA (856) 265-3054 (mobile) (302) 336-9693 (e-fax) anthony.lima@dot.gov website: hazmat.dot.gov From: Ron Sorrell [mailto:rsorrell@ghtesting.com] Sent: Tuesday, April 30, 2013 9:18AM To: Lima, Anthony (PHMSA) Subject: Telescoping box closure Hello Mr. Lima I have a customer who uses a full telescoping box which ships hazmate material. He assembles the box with a loaded base and then slides the top over the base. A band is put around the girth of the closed telescoping box as a security seal. If 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 telescoping box with the band and the tape and put both in the report. Now 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 use anything for the closure besides the lid of the telescoping box. We tested the telescoping box without any bands or tape 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 the telescoping box 2"-3" after drop considered closed or open". By 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 is the lid is a little less than half way up the base. Does this constitute a closed box? Thank you for your time. ftONALJ) J., SORR<RtL "' gh Package I Product Testing and Consulting,lnc. 4090 Thunderbird Lane 1 Fairfield, OH 145014 (Click For Directions) Phone: +(1) 513-870-0080 Ext. 1121 Mobile: +(1) 937-301-9920 2#

Page 5Email:rsorrell@ghtesting.com 1 Website: www.ghtesting.com Testing Facility Service Offerings: Distribution (ASTM I ISTA) Testing 1 Environmental/ Thermal Testing 1 UN/DOT Testing I lATA 650 I Data Acquisition Packaged Products upto 8000 lbs. 0'ista •:~e>mf!Hl LM'<:lW\1'00'\' This electronic message transmission contains information from gh Package & Product Testing and Consulting, Inc. which may be confidential or privileged. The information is intended to be for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us by telephone (1-513-870-0080) or by electronic mail (rsorrell@ghtesting.com) immediately. 3#