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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #07-0125 ([Dupont Automotive Systems] [Ms. Randylynn Bourassa])

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

Interpretation Response Details

Response Publish Date:

Company Name: Dupont Automotive Systems

Individual Name: Ms. Randylynn Bourassa

Location State: MI Country: US

View the Interpretation Document

Response text:

Jul 9, 2007

Ms. Randylynn Bourassa                 Reference No. 07-0125

Dupont Automotive Systems

Mid America Distribution

Safety Competency Lead

400 Groesbeck Highway

Mount Clemens, MI 48043

Dear Ms. Bourassa:

This is in response to your May 31, 2007 letter regarding closure requirements for steel drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you must remove and re-torque the head on open head steel drums you receive with the head already installed and torqued by the supplier or manufacturer.

The answer is no. A manufacturer or supplier of performance-oriented packagings may provide empty drums to customers in any stage of assembly. Under § 178.2(c), the manufacturer or other person certifying compliance with the requirements of Part 178, and each subsequent distributor of a packaging, must notify in writing each person to whom that packaging is transferred of all requirements not met at the time of transfer (e.g. bung closure torque specifications). The information specified in the notification must specify the type(s) and dimensions of the closures, including gaskets and any other components needed to ensure that the packaging is capable of successfully passing the applicable performance tests. It is the responsibility of the person filling and closing the drum to ensure that the closures not closed and torqued when they received the packaging are closed in accordance with the written notification supplied by the manufacturer or distributor.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

178.2(c), 173.22

Regulation Sections

Section Subject
173.22 Shipper's responsibility