Russell-Stanley — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, S.C. 20590 S.W. Special Programs Research and Administration JUL 28 2000 Mr. Earl V. Lind Ref No. 99-0254 Russell-Stanley 655 Route 202/206 Bridgewater. NJ 08807-1762 Dear Mr. Lind: This is in response to your letter asking whether a UN 3Hl packaging tested under an original design qualification without a "node" is a different design if the packaging is manufactured with a "node". I apologize for the delay in responding and hope it has not caused any inconvenience. You provided the following scenario: A change would be made to a UN 3H1 packaging that differs in only a minor respect from the original qualified design. This change would add a small "node" to the top of the container that can be punctured to allow easy emptying of the contents. The customer would be notified at the time of transfer that once the packaging had been punctured to empty the contents, the packaging would no longer be usable for hazardous materials, in effect making it a single use packaging. Except for the 28-day stacking test, design qualification testing has been successfully completed. A stack test was conducted during the periodic retest. The packaging replaces a previous UN 1H1 drum incorporating the puncture vent feature that has been discontinued. A different packaging is one that differs (i.e., not identical) from a previously produced packaging in structural design, size, material of construction, wall thickness, or manner of construction. A change in a component of a packaging which differ from the original design is a "different" packaging as defined in § 178.601(c)(4). The "UN 3H1" packaging, incorporating the puncture vent feature (i.e., node) for emptying, is a different design type. Such packaging tested without a "node" will not qualify a packaging with a "node" or nodule. Before a packaging goes into production, the design must be certified through performance of the design qualification tests prescribed in § 178.601(c)(1). A packaging may not be certified and marked as meeting a UN standard unless it has passed all design qualification tests, including the stacking test. The periodic retests is a quality control measure for newly marufactured packagings, and during 178.601 990254#

Page 2subsequent production of packagings of that design, periodic retests must be performed at least once every twelve months for single packaging, such as a "UN 3HI," non-removable head jerrican (see § 178.601(e)). I hope this satisfies your inquiry. If we can be of further assistance, please contact us Sincerely, in HIlls Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3•SEP-13-1999 08:53 RUSSELL-STANLEY CORP. 908 205 1944 r.U1/0C Russell-Stanley RUSSELL-STANLEY 685 Route 202/206, Bridgewater, NJ 08807-1762 TEL: (908) 203-9500 FAX: (908) 203-1940 September 10, 1999 Mr. Edward Mazzullo, Director Fax: 202-366-3012 Office of Hazardous Materials Standards, DHM-10 2 payes U.S. Department of Transportation Research and Special Programs Administration нечит 400 Seventh Street, SW $78,60, Washington, D.C. 20590 - 0001 99-0254 Re: Design Qualification Testing - 49 CFR § 178.601 (d) Dear Mr. Mazzullo, I am writing on behalf of Russell-Stanley Holdings, Inc.; 685 Route 202 / 206, Bridgewater, NJ 08807 - 1762 to request an interpretation regarding the design qualitication testing requirement as given in § 178.601(d) for a new or different packaging. This request is relates to UN 3H1 packagings that differ in minor aspects from the original qualified design. Specifically, we have made a minor change to meet a customer need. This change is he addition of a small node to the top of the container that the customer can puncture o allow easy emptying of the contents. Once punctured the jerrican is no longer usable for hazardous materials shipments, in effect making it a single use packaging. The customer is to be notified of this according to 49 CFR § 178.2(c). All design testing as per § 178.601(c) (1) except the 28-day stack test, § 178.606 (c)(1) have been completed successfully. The stack test authorized for the periodic retest § 178.606(c)(2) has been conducted. All tests were successful indicating that the change did not affect performance. This packaging replaces a previous UN 1H1 drum incorporating the described puncture vent feature that has been discontinued. The following Russell-Stanley manufacturing site makes, marks and sells this 3H1 jerrican: Russell-Stanley - Allentown (M-5303) 7132 Daniels Drive Allentown, PA 18106 610-530-7087 (v) 610-530-7038 (f)#

Page 4u -- We believe that this interpretation meets the definition of a minor change and does regulations. Due to current customer requirements we would appreciate an early response from you it possible. If you have any questions or need further information in order to expedite this request please do not hesitate to contact me at 908-203-9546. Thank you in advance for your assistance in this matter. sincerely, Causi Manager, Technology & Regulatory Affairs Earl V. Lind cc: J. Bevilaqua M. Hunter G. Lamond TOTAL P.Ø2#