Interpretation Response #01-0166 ([Taylor-Wharton] [Mr. Marc Richardson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Taylor-Wharton
Individual Name: Mr. Marc Richardson
Location State: AL Country: US
View the Interpretation Document
Response text:
August 15, 2001
Mr. Marc Richardson Ref. No. 01-0166
QA Manager
Taylor-Wharton
4075 Hamilton Blvd.
Theodore, AL 36582
Dear Mr. Richardson:
This is in response to your June 27, 2001 letter and subsequent phone conversations with Diane LaValle of my staff concerning manufacturing changes to UN specification lAl drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask what regulations apply to modifying a stock of already manufactured UN 1A1 drums by reducing the height of the top skirt by four inches according to the sketches you provided. Both configurations have been design qualified under the HMR.
You may modify your existing drums from a tested design type to a similar, but shorter, design type without the need for additional testing as long as the modification will not reduce the structural integrity of the certified drum and the manner of construction for the modified drums is the same as for the tested design type. In addition, drum markings must accurately reflect the modified drums.
I hope this satisfies your request.
Sincerely,
Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards
178.601
Regulation Sections
| Section | Subject |
|---|---|
| 178.601 | General requirements |