Interpretation Response #02-0283
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Apr 30, 2003
Mr. H. Perry Hock Reference No. 02-0283
gh Package & Product Testing
and Consulting, Inc.
325 Commercial Drive
Fairfield, OH 45014
Dear Mr. Hock:
This responds to your letter regarding the performance testing of UN standard packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you inquire whether the drop test height for a drum intended for a solid, may be adjusted as if it were a liquid with a specific gravity greater than 1.2, using the formula specified in § 178.603(e)(2)(ii). I apologize for the delay in responding.
The answer is no. Packagings intended for solids must be drop tested with either the hazardous material to be transported or a non-hazardous material having essentially the same physical characteristic according to the drop heights specified in § 178.603(e)(1). You may, however, apply for an approval authorizing a different test method than those prescribed under § 178.601(h). The procedures for applying for an approval are specified in § 107.705.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 178.603||Drop test|