Interpretation Response #01-0115
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
November 26, 2001
Mr. H. Perry Hock Reference No: 01-0115
gh Package & Product Testing
and Consulting, Inc.
325 Commercial Drive
Fairfield, OH 45014
Dear Mr. Hock:
Diane LaValle of my staff, requesting clarification of the requirements for testing of packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:
Q1. You are testing a combination packaging consisting of 4 one-gallon plastic inner receptacles in a fiberboard box. The manufacturer wants the packaging to be certified at the highest possible maximum gross weight. When you raise the weight of the packaging by adding lead shot or sand, the packagings fail. If they are tested with the actual high specific gravity (SG) material that will be transported, they pass. You ask if you may use the formula provided in § 178.603(e)(2)(ii) but work it backwards to determine the specific gravity to which a packaging may be certified. In other words, you want to determine the maximum height at which a packaging will pass the drop test and then work backwards to determine the corresponding SG. You ask what maximum gross weight should be marked on a packaging where the packaging was filled with water and passed a drop test at a height of 4.416 feet. You propose to perform the necessary calculation as follows:
Packing Group II: SG x 3.3 feet [§ 178.603(e)(2)(ii)]
SG = 4.416 feet ÷ 3.3 feet SG =1.33
A. You may determine specific gravity by using the equation in § 178.603(e)(2)(ii) in reverse. In your scenario using 1.33 SG, 4 one-gallon containers plus the tare weight of 3 pounds, the packaging may be certified to 23.1 kg. This is calculated by taking the rated capacity of the packaging in liters (4 gallons 15.14 liters) times the specific gravity (1.33 as calculated above) to get the maximum gross weight in kilograms [§ 173.24(b)(3)]. We note that this calculation does not leave any margin for error; the package failed at an incremental increase in drop height. Since each packaging must be capable of passing all the performance tests at any time during transportation, we recommend that you reduce the authorized specific gravity some reasonable amount so as to provide a greater margin for variation in performance of the production packagings.
Q2. May the maximum gross weight of a packaging be marked to I decimal place or must it be a whole number rounded down?
A. The maximum gross weight for a packaging may appear as a whole number rounded down or may appear rounded to the first decimal.
Q3. May the specific gravity be marked on a packaging to 2 decimal places? How should it be rounded? Should the actual SG be used to determine drop height or the rounded down SG?
A. As provided by § 178.503(a)(4)(i), single packagings intended to contain liquid are marked with the specific gravity rounded down to the first decimal and may be omitted when the specific gravity does not exceed 1.2. The actual SG should be used to determine drop height.
I hope this information is helpful.
Edward T. Mazzullo
Director, Office of Hazardous
|§ 178.603||Drop test|