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Interpretation Response #00-0250 ([Mr. Lane Arbittier])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Lane Arbittier

Location State: CA Country: US

View the Interpretation Document

Response text:

March 23, 2001


Mr. Lane Arbittier                       Ref. No. 00-0250
13533 Caminito Carmel

Del Mar, CA 92014

Dear Mr. Arbittier:

This is in response to your letter of August 30, 2000, requesting clarification of the capacity requirements for jerricans under the Hazardous Materials Regulations (HMR;49 CFR Parts 171-180). Specifically you ask if a plastic jerrican may be certified to a 3H2 UN specification standard
if the capacity exceeds 16 gallons.

For purposes of distinguishing between bulk packagings and non-bulk packagings, definitions for these terms in § 171.8 limit the maximum capacity of a non-bulk packaging to 450 liters, regardless of whether it is intended for liquids or solids.  A non-bulk packaging for solids is further limited to a maximum net mass of 400 kilograms.

With regard to § 178.509, a UN 1H1 or 1H2 plastic drum as a receptacle for solids is limited to both a maximum net capacity of,450 liters and a maximum net mass of 400 kilograms through application of the definitions in § 171.8 and the criteria in paragraphs (b)(7) and (b)(8) of § 178.509 However, the § 171.8 criteria are not relevant to capacity and mass limitations for a UN 3H1 or 3H2 jerrican because the jerrican is limited to sizes which do not approach the bulk/non-bulk thresholds.  Therefore, it is our determination that a jerrican as a receptacle for liquids is limited only to a maximum capacity of 60 liters as specified in § 178.509(b)(7) and a jerrican as a receptacle for solids is limited only to a maximum net mass of 120 kilograms as specified in § 178.509(b)(8). It is our understanding that this determination is consistent with application of size limitations in international regulations based on the United Nations Recommendations.  We intend to clarify these provisions in future rulemaking action.

In response to your specific inquiry and based on the foregoing, you may manufacture a UN 3H2 jerrican which is intended to contain no more than 75 pounds (approximately 34 kilograms) of solids only and has an internal volume of 17 gallons (approximately 64 liters).  Since the maximum capacity of the package exceeds 60 liters, it may not be used for liquids.

I trust this satisfies your inquiry.  If we can be of further assistance, please contact us.



Edward T. Mazzullo
Director, Office of Hazardous Materials Standard


Regulation Sections

Section Subject
178.509 Standards for plastic drums and jerricans