Interpretation Response #08-0129 ([Volunteer Drum] [Mr. Jack Oody])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Volunteer Drum
Individual Name: Mr. Jack Oody
Location State: TN Country: US
View the Interpretation Document
Response text:
June 18, 2008
Mr. Jack Oody
Volunteer Drum
3311 John Sevier Highway
Knoxville, TN 37914
Ref. No.: 08-0129
Dear Mr. Oody:
This is in response to your May 1, 2008 letter requesting clarification of the shipper’s responsibility for determining that a packaging is authorized under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the HMR require the shipper to maintain a copy of the original test report for a drum manufactured to a DOT specification, and whether a single test report may be used for DOT specification drums that are manufactured using different dimensions than the originally tested design-type.
The shipper is required to determine that a packaging or container is an authorized packaging under the HMR (see
§ 173.22(a)(2)). In making that determination, the shipper may accept the packaging manufacturer’s certification marking on the drum (see § 173.22(a)(3)). The HMR do not require the shipper to maintain a copy of the original test report; however, the packaging manufacturer must make the test report available to the user of a packaging upon request (see
§ 178.601(l)). In addition, a DOT specification drum produced with reductions in the external dimensions (i.e., length, width, or diameter) of up to 25 percent of the dimensions of a tested packaging may be used without additional testing provided an equivalent level of performance is maintained, and the packaging is identical to the tested design-type in all other respects (see § 178.601(g)(3)).
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
173.22(a)(2) 178.601(g)(3)
Regulation Sections
| Section | Subject |
|---|---|
| 173.22 | Shipper's responsibility |
| 178.601 | General requirements |