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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

Regulation Sections