{"operation":"document","citation":"17-0028","title":"Ball Food Aersol — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-05-25","effective_on":null,"summary":"17-0028 response to Ball Food Aersol concerning 178.33.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0028.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0028.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-17-0028","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/170028.pdf","body":"<<<PAGE 1>>>\n\nDirector, Technical Services\nBall Food & Aerosol\n9343 W. 108th Circle\nWestminster, CO 80021\nReference No. 17-0028\nDear Mr. Blum:\nThis letter is in response to your March 21, 2017, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the wall thickness of\nDepartment of Transportation (DOT) Specification 2P and 2Q inner non-refillable metal\nreceptacles.\nWe have paraphrased and answered your questions as follows:\nQ1. You ask how wall thickness is defined and if it denotes the thickness of the steel substrate\nor the combined thickness of the steel and any applied polymeric liners.\nA1. Wall thickness is the thickness of the material as specified in §§ 178.33-5 and 178.33a-5\nfor DOT Specification 2P and 2Q containers, respectively. This does not include any\napplied polymeric liners that may be added.\nQ2.\nYou ask if and/or when rounding up the wall thickness measurement is allowed. You\nfurther provide an example asking if a wall thickness measured at 0.0066 inch meets the\n0.007-inch requirement for DOT Specification 2P containers.\nA2.\nSection 178.33-7 states, \"The minimum wall thickness for any container shall be 0.007\ninch.\" Therefore, rounding up is not acceptable as the wall thickness would not meet the\nminimum requirement.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nTHen too\nT. Glenn Foster\nChief, Regulatory Review and Reinvention\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nPlease submit this as a letter of interpretation. Please let me know if you have any questions.\nThanks,\nJordan\nFrom: Blum, John J (John) [mailto:JBLUM@BALL.COM]\nSent: Tuesday, March 21, 2017 10:38 AM\nTo: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov>\nSubject: Request for formal Letter of Interpretation\nI have two questions that I'd like a formal answer on from DOT. It applies to 49 CFR 178.33 and 178.33a - specifically\nsection 7 - wall thickness.\nQuestion 1: How is wall thickness defined? For example, if you have a container manufactured with a steel substrate\ncoated with a polymeric liner (either inside or outside or both), is the wall thickness the thickness of the steel substrate\nor the combined thickness of the steel and any applied polymeric liners?\nQuestion 2: Thickness for DOT-2P and DOT-2Q, are .007 and .008\" respectively in 178.33(7) and 178.33a(7). If the\nminimum wall thickness is measured at .0066\", does this qualify as .007\" for DOT-2P? When is rounding up allowed or\nnot allowed?\nRespectfully Submitted,\nJohn\nJohn J. Blum, Ph.D.\nDirector, Technical Services\nBall Food & Aerosol\n9343 W. 108th Circle\nWestminster, CO 80021-3682\nPhone/Mobile: 847.414.5432\nE-Mail: jblum@ball.com\nThis message and any enclosures are intended only for the addressee. Please\nnotify the sender by email if you are not the intended recipient. If you are\nnot the intended recipient, you may not use, copy, disclose, or distribute this\nmessage or its contents or enclosures to any other person and any such actions\nmay be unlawful. Ball reserves the right to monitor and review all messages\nand enclosures sent to or from this email address.","truncated":false,"body_characters":3169}