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Interpretation Response #00-0219

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

Interpretation Response Details

Response Publish Date: 08-18-2000
Company Name: Black Forest Marketing, LLC    Individual Name: Mr. Tom Leftwich
Location state: SC    Country: US

View the Interpretation Document

Response text:

August 18, 2000


Mr. Tom Leftwich                         Ref. No. 00-0219
Black Forest Marketing, LLC
24 Vardy St. Suite 101-D
Greenville, SC 29601

Dear Mr. Leftwich:

This is in response to your August 8, 2000 letter regarding 49 CFR 178.504. Specifically, you ask if a closed head drum that is manufactured with a 3 inch opening meets the requirements of §178.504(b)(5).

Section 178.504(b)(5) states that openings in the bodies or heads of non-removable head (1A1) drums may not exceed 7.0 cm (3.0 inches) in diameter.  As specified in § 171.10 (a), the SI (metric) unit is the regulatory standard.  A U.S. standard or customary unit appearing in parentheses following the SI unit is provided for information only and is not intended to be the regulatory standard.  Therefore, 7.0 cm, not 3.0 inches is maximum opening allowed on a UN 1A1 steel drum. Using the conversion factor in § 171.10(c) for length, a more precise U.S. standard measure would be 2.7559 inches.

I hope this information is helpful.



Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards



Regulation Sections

Section Subject
§ 178.504 Standards for steel drums