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Interpretation Response #02-0148

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

Interpretation Response Details

Response Publish Date: 07-10-2002
Company Name: gh Package & Product Testing and Consulting, Inc.    Individual Name: H. Perry Hock
Country: US

View the Interpretation Document

Response text:

Jul 10, 2002

Mr. H. Perry Hock                 Reference No. 02-0148
gh Package & Product Testing and Consulting, Inc.
325 Commercial Drive
Fairfield, OH 45014
Dear Mr. Hock:

This is in response to your May 26, 2002 letter concerning UN specification pacakaging testing under the Hazardous Materials Regulations (HMR; 49 CFR, parts 171-180).  Specifically, you request clarification on the testing for UN 1A2 drum designed with and without a gasket between the lid and the drum.  You ask if the six required drops for the drop test in § 178.603 could be performed on the drams and lids without the gasket, then perform three additional top diagonal drops on previously untested drums with the lids containing the gasket.  You would then certify the drum. as not having a gasket and the drum would also have an alternative closure with a gasket.

Steel drums with and without a gasket would be considered to be different packagings under § 178.60 1 (c)(4) and § 178.601 (g)(8).  Thus, you would have to perform separate drop tests on the two types of drums you wish to manufacture to UN specifications.  In answer to your follow-up question asking if closed head drums having alternate bung caps could be tested in the way you proposed, if you meet the provisions of § 178.601 (g)(5) (Variation 5), then only the requirements of that section need apply.  If your change in bung caps does not meet the requirements under Variation 5 then that package would be considered a different packaging under § 178.60 1 (c)(4) and § 178.601 (g)(8) and would require the full drop test in order to be a UN Specification packaging.

I hope this satisfies your request.


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


Regulation Sections

Section Subject
§ 178.603 Drop test