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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
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.



Edward T. Mazzullo
Director, Office of Hazardous
Materials  Standards


Regulation Sections

Section Subject
178.601 General requirements