PHMSA Response Letter

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October 29, 2009

Mr. John A. McQuaid
Industrial Packaging Alliance of North America
IPANA/SSCI
PO Box 100907
Arlington, VA 22210

Ref. No.: 09–0185

Dear Mr. McQuaid:

This responds to your August 5, 2009 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171–180) to the manufacturing and testing of steel drums. Your questions are paraphrased and answered below.

Q1. Does a change in the type of rolling hoops (w-style vs. standard) used in the production of a 55-gallon steel drum constitute a design change that requires new qualification testing as prescribed in § 178.601(g)(8).

A1: No. A change in the type of rolling hoops (w-style vs. standard) does not qualify as a design change requiring new qualification testing under the provisions of § 178.601(g)(8).

Q2: When testing 1A2 steel drums for solids, is it permissible to use both bagged and loose material inside the drum to make the materials easier to re-use in later packaging testing?

A2. Yes, provided the use of the bagged and loose material does not interfere with any potential loss of contents during testing of the drum. In addition, the material must be of the same or higher specific gravity as the material to be transported and its other physical properties (grain, size, viscosity) that might influence the results of the required tests must correspond as closely as possible to those of the hazardous material to be transported. This includes assuring that the bags of material are interspersed evenly throughout the package and not placed at the top or bottom of the drums as to interfere with the testing of the package.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

178.601(g)(8)