Interpretation Response #07-0153
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Nov 19, 2007
Mr. H. Perry Hock
President and Technical Director
gh Package and Product Testing and
4090 Thunderbird Lane
Fairfield, OH 45014
Ref. No.: 07-0153
Dear Mr. Hock:
This responds to your August 7, 2007 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) requirements applicable to packaging test samples. Specifically, you ask about the requirements for using a non-hazardous material in place of a hazardous material when testing sample packagings.
Section 178.602(c) authorizes the use of non-hazardous materials in sample packagings that will be tested in accordance with Subpart M of Part 178 of the HMR. The non-hazardous material must have similar physical characteristics, including the same or higher specific gravity, to the hazardous material for which the packaging will be used.
Requirements for conducting the drop test are specified in § 178.603. Paragraph (c) of this section addresses preparation for the drop test of certain types of plastic packagings. In accordance with this paragraph, packagings must be tested when the temperature of the sample packaging and its contents has been reduced to -18° C or lower. Test liquids must be kept in the liquid state. If necessary to ensure that the test liquid remains in a liquid state, anti-freeze may be added to the test liquid. In this situation, water/anti-freeze solutions with a minimum specific gravity of 0.95 for testing at -18° C or lower are acceptable test liquids. Note that the specific gravity specified in § 178.603(c) applies only when the use of a water/anti-freeze solution is necessary to ensure that the test liquid remains in a liquid state. If the use of a water/anti-freeze solution is not necessary to ensure that the material remains in a liquid state, the requirements specified in § 178.602(c) applicable to the use of non-hazardous materials for testing sample packagings apply.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 178.603||Drop test|