Interpretation Response #05-0279 ([Regulatory Resources, Inc.] [Mr. Wade Winters])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 12/13/2005

Company Name: Regulatory Resources, Inc.

Individual Name: Mr. Wade Winters

Location State: OR Country: US

View the Interpretation Document

Response text:

Dec 13, 2005

Mr. Wade Winters                          Reference No. 05-0279
Regulatory Resources, Inc.
240 Joshua Road
Kennewick, WA 99338

Dear Mr. Winters:

This is in response to your November 1, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on the free drop test for Type 7A packages specified in § l73.465(c).

It is your understanding that center of gravity over impact point testing is not a required drop test orientation for a Type 7A package, unless such an orientation would impart maximum damage to the package.

Your understanding is correct. A Type 7A package, with its contents, must be capable of withstanding a free drop test. The specimen must drop onto the target so as to suffer maximum damage to the safety features being tested. The person conducting the free drop test must determine the orientation that will produce the maximum damage.

I hope this information is helpful. Please contact us if you require additional assistance.
Chief, Standards Development Office of Hazardous Materials Standards

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

173.465(c)

Regulation Sections