Interpretation Response #08-0184 ([Department of the Army, USAMC LOGSA Packaging Storage and Containerization Center] [Ms. Charlotte A Lent])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Department of the Army, USAMC LOGSA Packaging Storage and Containerization Center
Individual Name: Ms. Charlotte A Lent
Location State: PA Country: US
View the Interpretation Document
Response text:
August 18, 2008
Ms. Charlotte A Lent
Chief, USAMC LOGSA Packaging
Storage and Containerization Center
11 Hap Boulevard
Tobyhanna, PA 18466-5097
Ref. No.: 08-0184
Dear Ms. Lent
This is in response to your July 10, 2008 letter regarding non-bulk performance-oriented package testing under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the HMR restrict test substances for non-bulk packages designed to contain a liquid hazardous material to liquids having the same or higher specific gravity than water and prohibit the substitution of solid materials as a replacement test product for liquids.
According to § 178.602(c), it is permissible to use additives, such as bags of lead shot, to achieve the requisite total package mass so long as they are placed so that the test results are not affected. You suggest that bags of lead shot cannot be placed in a way that will not affect drop test results because load distribution and shock absorption are affected and the physical properties of bags lead shot and other solids are materially different than a liquid.
If a packaging passes the drop test when tested with bags of lead shot and liquid, but would fail if tested with water or a liquid substance with the same properties as the material to be transported, the results of the test have been affected. Thus, bags of lead shot are not a suitable additive.
You may petition for a rule change if you believe that a modification should be considered. Procedures for submitting a petition for rulemaking are in § 106.95.
I hope this answers your inquiry.
Sincerely,
Susan Gorsky
Acting Chief, Standards Development
Office of Hazardous Materials Standards
178.602(c)
Regulation Sections
| Section | Subject |
|---|---|
| 178.602 | Preparation of packagings and packages for testing |