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Interpretation Response #03-0039 ([Baker Hughes] [Mr. John W. Miggins])

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

Interpretation Response Details

Response Publish Date:

Company Name: Baker Hughes

Individual Name: Mr. John W. Miggins

Location State: TX Country: US

View the Interpretation Document

Response text:

Mar 19, 2003

Mr. John W. Miggins                Reference No. 03-0039
Product Safety/Transportation Specialist
Baker Hughes
12645 West Airport Boulevard
Sugar Land, Texas 77478-5050

Dear Mr. Miggins:

This is in response to your letter requesting clarification of the packaging requirements in § 173.226(b) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if a 54 gallon DOT 4BW cylinder may be used as an inner packaging for a Division 6.1, Packing Group I, Hazard Zone A material.  You state that the DOT 4BW cylinder meets or exceeds the performance standards of a lAl steel drum which is an authorized inner packaging.

The answer is no.  Section 173.226(b) does not authorize a DOT 4BW cylinder as an inner packaging.  The drums authorized as inner packagings in § 173.226(b), as well as the outer drums, must conform to the performance test requirements of subpart M of part 178 of the HMR at the Packing Group I performance level.  A DOT 4BW cylinder is manufactured to a specific design specification instead of a performance standard.  Therefore, use of a DOT 4BW cylinder as the inner packaging of a UN lAl drum for a Hazard Zone A material must be authorized under the terms of a DOT exemption.

I trust this satisfies your inquiry.



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


Regulation Sections

Section Subject
173.22 Shipper's responsibility