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Interpretation Response #01-0040

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

Interpretation Response Details

Response Publish Date: 02-28-2001
Company Name: HMT Associates, L.L.C.    Individual Name: Mr. E.A. Altemos
Location state: DC    Country: US

View the Interpretation Document

Response text:

FEB 28, 2001


Mr. E.A. Altemos                     Ref. No. 01-0040
HMT Associates, L.L.C.
1850 K Street, N.W. Suite 200
Washington, DC 20006-3500

Dear Mr. Altemos:

This is in response to your letter of February 7,2001, regarding the standards for UN specification drums found in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you inquire about the opening size requirements distinguishing a non-removable head drum (e.g., 1 AI) from a removable head drum (e.g., lA2) found in § 178.504.

You describe a stainless steel drum with all welded construction except for a short, 20 mm high neck that is 72 mm in diameter (inside). This is welded to the top of the drum. A flat, stainless steel plate and gasket covers the hole and is secured with a circumferential clamp held by two bolts through the ears of the clamp. The flat plate on top has two openings of not more that 18.3 rom through which the drum is filled arid emptied. You ask if this drum conforms to the requirements of § 178.504(b)(5), which limits the diameter of openings on non-removable, lAl drums to 70 mm.

The answer is no. The 72 mm neck on the drum constitutes an opening, even though the filling and emptying of the drum occurs through smaller holes drilled into the plate covering the opening, because the plate covering the neck is removable. We recommend certifying this drum as a lA2 removable head drum or applying for an approval in accordance with § 178.601(h) to permit an opening larger than 70 mm.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
§ 178.504 Standards for steel drums