Interpretation Response #00-0247 ([Honeywell International Inc.] [Ms. Barbara Konrad])

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

Interpretation Response Details

Response Publish Date: 01/31/2001

Company Name: Honeywell International Inc.

Individual Name: Ms. Barbara Konrad

Location State: NJ Country: US

View the Interpretation Document

Response text:

January 31, 2001

Ms. Barbara Konrad                         Ref.  No: 00-0247
Honeywell International Inc.
101 Columbia Road
Morristown, NJ 07962

Dear Ms. Konrad:

This is in response to your letter regarding closure procedures for a drum under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask whether it is permissible to deviate from a manufacturer's recommended closure torque for a specification drum if there is sufficient evidence collected by the shipper that the recommended torque could result in a leaking package.  You provided the following scenario:

You use a UN 1H1 drum manufactured by Russell-Stanley.  This is the only drum on the market suitable for your product.  The recommended torque closure from the manufacturer is 25 foot-pounds with no allowable tolerance range.  You found that when closures of filled drums are torqued to 25 foot-pounds, severe cupping of the drum closure results.  You believe this makes the drums unsuitable and unsafe for transportation.  When you checked older versions of the same manufacturer closure instructions for the same drum, a closure torque of 20 foot-pounds was recommended.  Internal studies confirm that closing the drums to a torque of 20 foot-pounds, significantly improves closure, does not deform the bung and results in an overall safer package.

If deterioration of a closure is occurring, the manufacturer should be made aware of the deficiency.  You should request that the manufacturer revise its notification to customers to specify an appropriate closure torque.  Alternatively, you may use Variation 5 (§ 178.601(g)(5)) to change the torque closure on a UN certified drum.  As provided by this variation, a closure device may differ from a tested design type provided an equivalent level of performance is maintained and qualifying tests (leakproofness test, hydrostatic pressure test and the stacking test) are successfully passed.  A test report must be developed and attached to the original test report or closure notification.

I hope this information is helpful.

Sincerely,

Edward T. Mazzullo
Director
Office of Hazardous Materials Standards

178.509

Regulation Sections