{"operation":"document","citation":"99-0254","title":"Russell-Stanley — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-07-28","effective_on":null,"summary":"99-0254 response to Russell-Stanley concerning 178.601.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0254.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0254.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0254","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990254.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, S.C. 20590\nS.W.\nSpecial Programs\nResearch and\nAdministration\nJUL 28 2000\nMr. Earl V. Lind\nRef No. 99-0254\nRussell-Stanley\n655 Route 202/206\nBridgewater. NJ 08807-1762\nDear Mr. Lind:\nThis is in response to your letter asking whether a UN 3Hl packaging tested under an original design\nqualification without a \"node\" is a different design if the packaging is manufactured with a \"node\". I\napologize for the delay in responding and hope it has not caused any inconvenience.\nYou provided the following scenario:\nA change would be made to a UN 3H1 packaging that differs in only a minor respect\nfrom the original qualified design. This change would add a small \"node\" to the top of\nthe container that can be punctured to allow easy emptying of the contents. The\ncustomer would be notified at the time of transfer that once the packaging had been\npunctured to empty the contents, the packaging would no longer be usable for\nhazardous materials, in effect making it a single use packaging. Except for the 28-day\nstacking test, design qualification testing has been successfully completed. A stack test\nwas conducted during the periodic retest. The packaging replaces a previous UN 1H1\ndrum incorporating the puncture vent feature that has been discontinued.\nA different packaging is one that differs (i.e., not identical) from a previously produced packaging in\nstructural design, size, material of construction, wall thickness, or manner of construction. A change in\na component of a packaging which differ from the original design is a \"different\" packaging as defined\nin § 178.601(c)(4). The \"UN 3H1\" packaging, incorporating the puncture vent feature (i.e., node) for\nemptying, is a different design type. Such packaging tested without a \"node\" will not qualify a\npackaging with a \"node\" or nodule.\nBefore a packaging goes into production, the design must be certified through performance of the\ndesign qualification tests prescribed in § 178.601(c)(1). A packaging may not be certified and marked\nas meeting a UN standard unless it has passed all design qualification tests, including the stacking test.\nThe periodic retests is a quality control measure for newly marufactured packagings, and during\n178.601\n990254\n\n<<<PAGE 2>>>\n\nsubsequent production of packagings of that design, periodic retests must be performed at least once\nevery twelve months for single packaging, such as a \"UN 3HI,\" non-removable head jerrican (see\n§ 178.601(e)).\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us\nSincerely,\nin HIlls\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n•SEP-13-1999\n08:53\nRUSSELL-STANLEY CORP.\n908 205 1944 r.U1/0C\nRussell-Stanley\nRUSSELL-STANLEY\n685 Route 202/206, Bridgewater, NJ 08807-1762\nTEL: (908) 203-9500 FAX: (908) 203-1940\nSeptember 10, 1999\nMr. Edward Mazzullo, Director\nFax: 202-366-3012\nOffice of Hazardous Materials Standards, DHM-10\n2 payes\nU.S. Department of Transportation\nResearch and Special Programs Administration\nнечит\n400 Seventh Street, SW\n$78,60,\nWashington, D.C. 20590 - 0001\n99-0254\nRe: Design Qualification Testing - 49 CFR § 178.601 (d)\nDear Mr. Mazzullo,\nI am writing on behalf of Russell-Stanley Holdings, Inc.; 685 Route 202 / 206,\nBridgewater, NJ 08807 - 1762 to request an interpretation regarding the design\nqualitication testing requirement as given in § 178.601(d) for a new or different\npackaging.\nThis request is relates to UN 3H1 packagings that differ in minor aspects from the\noriginal qualified design.\nSpecifically, we have made a minor change to meet a customer need. This change is\nhe addition of a small node to the top of the container that the customer can puncture\no allow easy emptying of the contents. Once punctured the jerrican is no longer\nusable for hazardous materials shipments, in effect making it a single use packaging.\nThe customer is to be notified of this according to 49 CFR § 178.2(c).\nAll design testing as per § 178.601(c) (1) except the 28-day stack test, § 178.606\n(c)(1) have been completed successfully. The stack test authorized for the periodic\nretest § 178.606(c)(2) has been conducted. All tests were successful indicating that\nthe change did not affect performance.\nThis packaging replaces a previous UN 1H1 drum incorporating the described\npuncture vent feature that has been discontinued.\nThe following Russell-Stanley manufacturing site makes, marks and sells this 3H1\njerrican:\nRussell-Stanley - Allentown (M-5303)\n7132 Daniels Drive\nAllentown, PA 18106\n610-530-7087 (v)\n610-530-7038 (f)\n\n<<<PAGE 4>>>\n\nu --\nWe believe that this interpretation meets the definition of a minor change and does\nregulations.\nDue to current customer requirements we would appreciate an early response from\nyou it possible. If you have any questions or need further information in order to\nexpedite this request please do not hesitate to contact me at 908-203-9546.\nThank you in advance for your assistance in this matter.\nsincerely, Causi\nManager, Technology & Regulatory Affairs\nEarl V. Lind\ncc: J. Bevilaqua\nM. Hunter\nG. Lamond\nTOTAL P.Ø2","truncated":false,"body_characters":5158}