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Interpretation Response #02-0283 ([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:

Apr 30, 2003

Mr. H. Perry Hock                 Reference No. 02-0283
Technical Director
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


Regulation Sections

Section Subject
178.603 Drop test