Interpretation Response #02-0133 ([gh Package/Product Testing & Consulting, Inc] [Bernhard Bieri, III])

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

Interpretation Response Details

Response Publish Date: 07/17/2002

Company Name: gh Package/Product Testing & Consulting, Inc

Individual Name: Bernhard Bieri, III

Location State: OH Country: US

View the Interpretation Document

Response text:

Jul 17, 2002

Mr. Bernhard Bieri, III                 Reference No. 02-0133
gh Package/Product Testing & Consulting, Inc.
325 Commercial Drive
Fairfield, OH 45014

Dear Mr. Bieri,

This responds to your April 25, 2002 letter requesting we consider alternative testing procedures to those under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80).  Specifically, you ask that we consider two options that you are recommending for retesting of previously certified UN hazardous material packages.  You state that these recommended testing procedures will help the environment and reduce waste and costs involved with UN hazardous materials testing.  Your further state that these recommended options are to be used only when agreed upon by the customer and testing laboratory performing the test.

You propose the following options: Option #1- The quantity of packs required for drop tests be reduced to three (3) packs with multiple drops performed on two (2) packs, and Option #2 - Use only two (2) complete filled packs for stack, vibration and drop testing.  You recommend these procedures for: (1) retest only when no substantial change in supplier or material has been made since previous tests and, (2) when both testing lab and customer preparing pack for distribution agree that past history of pack tests and field distribution show leakage of product or significant damage to product has not occurred.  Your premise for these recommendations are that any pack that withstands multiple tests and passes performs better than multiple packs of the same pack design that are subjected to only one (1) test per box.

Currently, the HMR do not authorize the test procedures identified in your letter.  In accordance with provisions in § 178.601(k), provided the validity of the test results is not affected and with the approval of the Associate Administrator, several tests may be performed on one sample.  You may submit an application for approval from the Associate Administrator to use fewer samples in testing in accordance with provisions in Subpart H- Approvals, Registrations and Submissions of the HMR.  You may also petition the Associate Administrator to establish, amend, or repeal a regulation under Subpart B ­Procedures for Adoption of Rules. (See § 106.31).

I hope this answers your inquiry.

Sincerely,

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

178.602

Regulation Sections