Interpretation Response #00-0148 ([Quality Control Department] [Mr. Colum O'Hara])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Quality Control Department
Individual Name: Mr. Colum O'Hara
Location State: NJ Country: US
View the Interpretation Document
Response text:
June 28, 2000
Mr. Colum O'Hara Ref. No. 00-0148
Phoenix Container, Inc.
Quality Control Department
1202 Airport Road
N. Brunswick, New Jersey 08902
Dear Mr. O'Hara:
This is in response to your letter dated May 9, 2000, requesting clarification of the drop test procedures for performance oriented packagings, such as lAl and 1A2 steel drums, under §178.603 (f)(1) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that you were advised on May 8, 2000, by the Hazardous Materials Information Center that equilibrium could be reached by letting the contents of the package settle. Specifically, you ask if this is an acceptable method to reach equilibrium inside a container once it has been drop tested.
There are several acceptable methods for achieving equilibrium between the internal and external pressures of the container. These methods include: letting the package sit for a time to allow the contents of the package to settle; or by drilling a hole into the vapor or air space to achieve equilibrium in the package after the drop test.
I hope this answers your inquiry.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
178.603