Interpretation Response #00-0102 ([Chemical Products Group] [Ms. Joyce Stratis])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Chemical Products Group
Individual Name: Ms. Joyce Stratis
Location State: PA Country: US
View the Interpretation Document
Response text:
May 16, 2000
Ms. Joyce Stratis Ref. No: 00-0102
FMC Corporation
Chemical Products Group
1735 Market Street
Philadelphia, PA 19103
Dear Ms. Stratis:
This is in response to your letter of April 12, 2000, requesting clarification on the packaging requirements for materials poisonous by inhalation under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80).
The packaging requirements of §173.227(b)(ii) state that the closure must be physically held in place by any means capable of preventing back-off or loosening of the closure by impact or vibration during transportation. You ask whether using a bead of silicone caulk around the bung closure meets the provisions of §173.227(b)(ii).
The means you have described for physically holding a bung closure in place is acceptable. I hope this information is helpful.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.227(b)(ii)