Interpretation Response #03-0090 ([Lansmont Corporation] [Ms. Tramy Lieu])

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

Interpretation Response Details

Response Publish Date: 06/24/2003

Company Name: Lansmont Corporation

Individual Name: Ms. Tramy Lieu

Location State: CA Country: US

View the Interpretation Document

Response text:

Jun 24, 2003

Ms. Tramy Lieu                Reference No.: 03-0090
Lansmont Corporation
1287 Reamwood Avenue
Sunnyvale, CA 94089

Dear Ms. Lieu:

This responds to your letter requesting clarification of the requirements for testing of packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions pertain to a 4G combination packaging with a glass inner packaging that contains a PG I liquid with a specific gravity (SG) of 1.7. The gross weight of the combination packaging is 14.3 kilograms. Your questions are paraphrased and answered as follows:

QI. The packagings are drop tested from a height of2.6 m, calculated per
§ 178.603(e)((2)((ii)(A) with water replacing the hazardous material. Must the packagings be drop tested at the gross weight of 14.3 kg?

AI. The answer is no. The increased drop height is used to simulate the higher specific
gravity.

Q2. May water be used in lieu of the hazardous material in the vibration test?

A2. Yes, water may be used to perform testing to determine if a non-bulk packaging is
capable of passing the vibration standard.

Q3. Does 49 CFR contain a formula for calculating the maximum gross weight of a package
If the specific gravity and drop height are defined.

A3. The answer is no, there is no formula to calculate the maximum gross weight of a
package if the specific gravity and drop height are defined. The drop height is based on the packing group and specific gravity of the material, not on "gross package weight." The maximum gross weight that may be marked on a package is based on meeting the required performance test standards, however, the maximum gross mass would be the combined weight of the liquid and the weight of all inner and outer packagings.

I trust this satisfies your inquiry.

Sincerely,

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

Regulation Sections