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Interpretation Response #02-0221 ([Alloy Products Corporation] [Peter El-Sabaaly])

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

Interpretation Response Details

Response Publish Date:

Company Name: Alloy Products Corporation

Individual Name: Peter El-Sabaaly

Location State: WI Country: US

View the Interpretation Document

Response text:

Dec 4, 2002

Mr. Peter El-Sabaaly                 Reference No. 02-0221
Director of Engineering
Alloy Products Corporation
P.O. Box 529
Waukesha, WI 53187-0529

Dear Mr. El-Sabaaly:

This responds to your August 16, 2002 letter requesting clarification on package testing requirements under the Hazardous Materials Regulations (HMR- 49 CFR Parts 171-180).  Specifically, you ask if the vibration standard under § 178.608 is required for the design qualification testing only and not the periodic retesting of packagings.

Your understanding of vibration standard is that the vibration test is required for the design qualification testing only and does not apply to the periodic retesting.  Your understanding is incorrect.  All performance tests for design qualification testing and periodic retesting under §§ 178.603, 178.604, 178.605, 178.606, or 178.607, must be performed in accordance with provisions in § 178.601(c)(1) and (c)(2) at the frequency specified in 178.601(e). These performance tests are required to be performed and packages must successfully pass these tests before they can be certified as a UN performance packaging authorized to carry hazardous materials.

However, as specified in § 178.608, each non-bulk packaging must be capable of withstanding, without rupture or leakage, the vibration test procedure outlined in this section.  This capability can be demonstrated through the packaging performance history using this type of packaging or by performing the vibration test.  The vibration test is not required to be performed for non-bulk packagings.  For certain bulk packagings, such as intermediate bulk containers, the vibration test must be conducted for both design qualification and periodic retesting.

I hope this answers your inquiry.


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


Regulation Sections

Section Subject
178.601 General requirements