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Interpretation Response #01-0177 ([Vopak USA, Inc.] [Mr. Jay Jarvis])

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

Interpretation Response Details

Response Publish Date:

Company Name: Vopak USA, Inc.

Individual Name: Mr. Jay Jarvis

Location State: NC Country: US

View the Interpretation Document

Response text:

October 18, 2001

 

Mr. Jay Jarvis                                   Reference  No. 01-0177
Vopak USA, Inc.
334 Worth Street
Fayetteville, NC 28304

Dear Mr. Jarvis:

This responds to your July 13, 2001 letter requesting clarification on cleaning and testing a UN 1 H 1 drum for reuse under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Specifically, you ask whether your new air pressure test satisfies requirements for reuse of packagings in § 173.28.

You have developed your own pressure testing machine that will apply 3 psi of air and hold it for the specified time frame.  You want to air pressure test your drums in order to make them acceptable for reuse for transporting hazardous materials on common carriers.

Based on the information provided in your letter, it is the opinion of this Office that your new method of pressure testing conforms to Appendix B to Part 178 - Alternate Leakproofness Test Methods and with the reuse provisions in § 173.28(b). However, leakproofness testing at 3 psi will only be suitable for drums marked for PG II or PG III liquids; PG I materials require a leakproofness test conducted at 7 psi.

I hope this answers your inquiry.

Sincerely,

 

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

173.28

Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings