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Interpretation Response #02-0232 ([gh Package &Product Testing and Consulting, Inc] [H. Perry Hock])

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

Interpretation Response Details

Response Publish Date:

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

Individual Name: H. Perry Hock

Location State: OH Country: US

View the Interpretation Document

Response text:

Mar 2 4, 2004

Mr. H. Perry Hock                                                                                Reference No. 02-0232
gh Package & Product Testing 
and Consulting, Inc.
32S Commercial Dr.
Fairfield, OH 45014

Dear Mr. Hock:

This is in response to your letter requesting clarification of the requirements of the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180) regarding the marking and testing of a combination packaging.  Your questions are paraphrased and answered below.

Q1 One combination packaging consists of an outer 4G fiberboard box and an inner metal can with a gross mass of 7.3 kg. Another combination packaging consists of an identical outer 4G fiberboard box and an inner glass bottle with a gross mass of 5.3 kg.  May the packagings be marked with the highest gross mass tested, or must the packaging be dual marked with both the higher and the lower gross weights?

Al. For a packaging containing the inner glass packaging, in accordance with § 178.503(a)(3), it is not appropriate to mark the packaging to a higher gross weight than for which it was tested.  The packagings may be marked with both specification markings.  However, unless the non-applicable marking is covered or obliterated, the dual marks may cause confusion and could result in a violation of the regulations.  The conditions for use would have to be clearly set forth in the notification to users required by § 178.2(c).

Q2. When testing a combination packaging and the specific gravity of the liquid is unknown, may we use the formula "PG drop height X desired gross mass ÷ actual package gross mass adjusted drop height," which is based on the desired gross mass of the packaging, to determine the adjusted drop height under 9 178-603 (e) (2) (ii)?

A2. The formula you presented in your letter is not in accordance with the formula provided in § 178.603(e)(2)(ii) of the HMR.  Based upon the formula and the information provided in your letter the minimum-acceptable drop height can be calculated without knowing the maximum specific gravity of the product that will be packaged.  The correct formula derived from the revised drop height calculations presented in § 178.6O3(e)(2)(ii) is as follows:

H = (M-T) X D/W

H = Drop height
M = Certified gross mass
T = Tare weight of packaging
D = Variable for correcting Packing Group (1.5, 1.0 or 67 meters)
W = Weight of water in kg or Volume of water in liters

Using the example from your letter (after converting to kg) the correct calculation is:

H = Drop height
M = 6.4 kg
T = 0.7 kg
D = 1.0 for Packing Group II
W = 3.8 liters or kg
H = (6.4-0.7) X 1.0/3.8 =  1.5 meters

Your formula provides for a drop height of:

H = 1.2 X 6.4/4.5 = 1.7 meters

If in all cases your formula provides for a height that is greater than the minimum required by the HMR, it is acceptable to use the greater height for package testing as the HMR provide the minimum requirements for testing a package.

I hope this information 'is helpful.  If you have additional questions, please contact this office.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

178.503, 178.602

Regulation Sections

Section Subject
178.503 Marking of packagings
178.602 Preparation of packagings and packages for testing