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Interpretation Response #07-0159 ([gh Package & Product Testing and Company] [Mr. H. Perry Hock  ])

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

Interpretation Response Details

Response Publish Date:

Company Name: gh Package & Product Testing and Company

Individual Name: Mr. H. Perry Hock  

Location State: OH Country: US

View the Interpretation Document

Response text:

Oct 18, 2007

Mr. H. Perry Hock                                 Reference No. 07-0159

President and Technical Director

gh Package & Product Testing and Company

4090 Thunderbird Lane

Fairfield, OH 45014

Dear Mr. Hock:

This is in response to your letter dated May 31, 2007 and subsequent telephone conversation with Ben Supko of my staff in regard to the IBC testing provided by the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the term "filled," as used in § 178.8l9(b)(1).

In preparation for the vibration test, § 178.819(b)(1) requires an IBC to be filled and closed as for shipment. The term "filled" represents the maximum permissible gross mass of the package - that is, an IBC marked with a 500 kg maximum gross mass must weigh 500 kg when subjected to the test. The requirement for performance of the vibration test on a "filled" package applies even if the end user plans to offer the package for transportation below its maximum permissible gross mass.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

Edward T. Mazzullo

Director

Office of Hazardous Materials Standards

178.819(b)(1)

Regulation Sections

Section Subject
178.819 Vibration test