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.
Sincerely,
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 |