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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 #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.


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