Ten-E Packaging Services, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S.Department Washington, D.C. 400 Seventh Street, S.W. 20590 Special Programs Research and Administration AUG 1 O 1999 Mr. Robert J. Ten Eyck Ref. No: 99-0054 Director, Technical Services Ten-E Packaging Services, Inc. 1666 County Road 74 Newport, Minnesota 55055 Dear Mr. Ten Eyck: This is in response to your letter of March 1, 1999, requesting clarification on the requirements for testing packagings under the Hazardous Materials Regulations (HMR; 49 CFR parts 171- 180). Specifically you ask whether each closure for a packaging used under Variation 5 of § 172.601(g) must be tested when the periodic design requalification is performed. The answer is no. Nothing in the HMR requires testing of each different closure used under Variation 5. I hope this information is helpful. Sincerely, Selm 763l6 Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 990054 178.601#

Page 2TENOE 3178.601 Setting the standard 99-0054 March 1, 1999 Edward Mazzullo Office of Hazardous Materials Standards DHM-10 U.S. DEPARTMENT OF TRANSPORTATION Research and Special Programs Administration 400 Seventh Street, S.W. Washington, DC 20590 Dear Ed: I am writing to request clarification on the use of selective testing provisions for single packagings found in Section 178.601(g)(5) of Title 49 CFR. Do.the periodic retesting provisions found in Section 178.601(e) apply to those packagings with different closure devices or gaskets qualified under the Variation 5 selective testing provisions? For example, a manufacturer design qualifies a 20 liter, UN 1H1 drum with a 2" pipe threaded plug and then employs selective testing Variation 5 to qualify alternative closures such as a 2" buttress plug, a crimp-on closure with pour spout and a friction-fit plug. When the 12 month periodic retest date arrives, is the manufacturer obligated to evaluate all the closure systems identified above or only the 2" pipe threaded plug design for which complete design qualification testing was originally conducted ? Your clarification on this testing matter is greatly appreciated. Sincerely, Robert J. Ten Evck/ Director, Technical Services TEN-E Packaging Services Inc. 1666 CoUnty Road 74 Hewport. Minnesota 55055 email:info@ten-e.com NOE NOH web:uwo.len-e.com 0671 4591430 ISO 9002 IS09002 phone#