Interpretation Response #00-0088 ([RIPA] [Mr. C.L. Pettit])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: RIPA
Individual Name: Mr. C.L. Pettit
Location State: MD Country: US
View the Interpretation Document
Response text:
April 19, 2000
Mr. C.L. Pettit Ref. No. 00-0088
Vice President, Regulatory and Technical Affairs
RIPA
8401 Corporate Drive
Landover, MD 20785-2224
Dear Mr. Pettit:
This is in response to your letter of March 20, 2000, concerning performance oriented packaging markings on drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 100- 1 80). Specifically you asked if a UN standard drum dual marked on the bottom to both a "Y" rating for liquids and an "X" rating for solids may be used for a PG I solid even though the drum is side marked with only the "Y" rating.
Section 178.3(a)(5) states that for packages with a gross mass of more than 30 kg (66 pounds), the markings or a duplicate of the markings must appear on the top or side of the package. The marking for the "X" rating would need to appear on the side of the drum if you use the packaging for that standard and your gross mass exceeds 30 kg.
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
178.3