Interpretation Response #02-0164 ([Spartanburg Stainless Products, Inc] [Scott Rosenberge])

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

Interpretation Response Details

Response Publish Date: 08/27/2002

Company Name: Spartanburg Stainless Products, Inc

Individual Name: Scott Rosenberge

Location State: SC Country: US

View the Interpretation Document

Response text:

Aug 27, 2002

Mr. Scott Rosenberger                     Reference No. 02-0164
Spartanburg Stainless Products, Inc.
P. 0. Box 3488
Spartanburg, SC 29304

Dear Mr. Rosenberger:

This is in response to your letter concerning marking UN specification drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your company manufactures 1A1 steel drums from two drawn shells.  You state that during the manufacturing process, when the flat blank is drawn and stretched into a shell, the steel will thin in certain areas and thicken in others.  You reference the "Die Makers Handbook" which states that thinning may be as much as 38% in the knuckle radius area. In your opinion, the tolerances found in ISO standard 3574(see § 178.503(a)(9)) are too tight and do not appear to apply to drawn shells.  Specifically, you ask if a greater tolerance is allowed how that should be reflected in the nominal thickness stamp.

The HMR do not recognize the "Die Makers Handbook" you reference in your letter.  Section 178.503(a)(9)(i) states that metal drums must be marked with the nominal thickness of the metal used in the body when the tolerance conforms to ISO Standard 3574.  ISO 3574 dimensions define the nominal thicknesses and corresponding minimum thickness for steel Sheets prior to subjecting the steel to any manufacturing processes, in your case drawing and stretching the sheets into shells used to form drums.  The minimum thickness and nominal dimensions indicated in ISO 3574 are not applicable for steel sheets after forming operations, such as drawing and stretching the steel sheet into shells, are completed.  The purpose of marking the drum with the ISO nominal thickness is to ensure safety in transportation by identifying the minimum permitted thickness of the drum, thereby indicating whether the Drum is or is not suitable for reuse or reconditioning.  Due to the unusual nature of your fabrication process, the drum should either be marked with the actual minimum thickness measured at the thinnest part of the Drum or the ISO 3574 nominal thickness that corresponds to the measured minimum thickness.

I hope you find this information helpful.  If you have further question, please do not hesitate to contact this office.

Sincerely,

Edward T. Mazzullo
Director, Office of Hazardous Materials Standards

178.503(a)(9)

Regulation Sections