Ball Food Aersol — Hazardous Materials Safety Interpretation

Page 1Director, Technical Services Ball Food & Aerosol 9343 W. 108th Circle Westminster, CO 80021 Reference No. 17-0028 Dear Mr. Blum: This letter is in response to your March 21, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the wall thickness of Department of Transportation (DOT) Specification 2P and 2Q inner non-refillable metal receptacles. We have paraphrased and answered your questions as follows: Q1. You ask how wall thickness is defined and if it denotes the thickness of the steel substrate or the combined thickness of the steel and any applied polymeric liners. A1. Wall thickness is the thickness of the material as specified in §§ 178.33-5 and 178.33a-5 for DOT Specification 2P and 2Q containers, respectively. This does not include any applied polymeric liners that may be added. Q2. You ask if and/or when rounding up the wall thickness measurement is allowed. You further provide an example asking if a wall thickness measured at 0.0066 inch meets the 0.007-inch requirement for DOT Specification 2P containers. A2. Section 178.33-7 states, "The minimum wall thickness for any container shall be 0.007 inch." Therefore, rounding up is not acceptable as the wall thickness would not meet the minimum requirement. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, THen too T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#

Page 2Please submit this as a letter of interpretation. Please let me know if you have any questions. Thanks, Jordan From: Blum, John J (John) [mailto:JBLUM@BALL.COM] Sent: Tuesday, March 21, 2017 10:38 AM To: INFOCNTR (PHMSA) < INFOCNTR.INFOCNTR@dot.gov> Subject: Request for formal Letter of Interpretation I have two questions that I'd like a formal answer on from DOT. It applies to 49 CFR 178.33 and 178.33a - specifically section 7 - wall thickness. Question 1: How is wall thickness defined? For example, if you have a container manufactured with a steel substrate coated with a polymeric liner (either inside or outside or both), is the wall thickness the thickness of the steel substrate or the combined thickness of the steel and any applied polymeric liners? Question 2: Thickness for DOT-2P and DOT-2Q, are .007 and .008" respectively in 178.33(7) and 178.33a(7). If the minimum wall thickness is measured at .0066", does this qualify as .007" for DOT-2P? When is rounding up allowed or not allowed? Respectfully Submitted, John John J. Blum, Ph.D. Director, Technical Services Ball Food & Aerosol 9343 W. 108th Circle Westminster, CO 80021-3682 Phone/Mobile: 847.414.5432 E-Mail: jblum@ball.com This message and any enclosures are intended only for the addressee. Please notify the sender by email if you are not the intended recipient. If you are not the intended recipient, you may not use, copy, disclose, or distribute this message or its contents or enclosures to any other person and any such actions may be unlawful. Ball reserves the right to monitor and review all messages and enclosures sent to or from this email address.#