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
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.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
178.603
Regulation Sections
| Section | Subject |
|---|---|
| § 178.603 | Drop test |