Interpretation Response #11-0187 ([Greif Packaging LLC] [Mr. Peter R. Apostoluk])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Greif Packaging LLC
Individual Name: Mr. Peter R. Apostoluk
Location State: OH Country: US
View the Interpretation Document
Response text:
October 14, 2011
Mr. Peter R. Apostoluk
Technical Director-Plastic and IBC Products
Greif Packaging LLC
366 Greif Parkway
Delaware, OH 43015
Ref. No. 11-0187
Dear Mr. Apostoluk:
This responds to your August 10, 2011 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-185). Specifically, you ask if the 6HA1 mark for a steel tight (non removable) head composite drum also applies to a steel open (removable) head composite drum.
The answer is yes. There is no distinction between closed and open head steel drums under identification code "6HA1." The identification code "6HA1" is the only authorized code under § 178.522(a) for a plastic receptacle within a protective steel drum. Therefore, code "6HA1" should be used for all steel drum composite packaging with inner plastic receptacles.
I hope this answers your inquiry. If you need additional assistance, do not hesitate to contact this office at (202) 366-8553.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
178.522