Interpretation Response #00-0237
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
April 11, 2001
Mr. William C. Shreves Reference No: 00-0237
Total Quality Control Associates
4712 Woodward Ave.
Downers Grove, IL 60515
Dear Mr. Shreves:
This is in response to your August 17, 2000 letter concerning the hydrostatic test prescribed in 49 CFR 178.605. Specifically, you state that one of your 2-inch closures also has a 3/4-inch closure in its center. You asked if the pressure applied into the packaging may be introduced through the 3/4-inch opening instead of adding another opening in the packaging.
If the closure has been previously hydrostatical. pressure tested, then this test method would be acceptable. If it has not been previously pressure tested, then the answer is no; the pressure may not be applied through the 3/4-inch opening. Section 178.602(a) and (e) requires that 1) each package and packaging must be closed in preparation for testing, and 2) the tests must be carried out on the packages prepared as if for actual shipment.
I hope this satisfies your request.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 178.605||Hydrostatic pressure test|