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Interpretation Response #09-0157 ([Hibrett Puratex] [Mr. John P. J. Madden])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hibrett Puratex

Individual Name: Mr. John P. J. Madden

Location State: NJ Country: US

View the Interpretation Document

Response text:

August 28, 2009




Mr. John P. J. Madden


Hibrett Puratex

7001 Westfield Avenue

Pennsauken, NJ 08110

Ref. No.: 09-0157

Dear Mr. Madden:

This responds to your letter dated July 10, 2009, regarding the stacking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about stacking packages containing either hazardous or non-hazardous materials on top of a skid containing four 55-gallon drums of Class 8 material.

Your letter provides several examples of stacking configurations, as follows:

Example 1: 4 x 55 gallon drums of a Class 8 (Corrosive) on a skid stretch wrapped with 5 gallon pails or 4 x 1-gallon cases stretch wrapped on top.

Example 2: 4 x 55 gallon drums of a Class 8 (Corrosive) on a skid stretch wrapped with several 50 pound bags stretch wrapped on top.

Example 3: 4 x 55 gallon drums of a Class 8 (Corrosive) on a skid stretch wrapped with empty, new containers secured on top.

Section 178.606 contains requirements for stacking non-bulk packagings. All non-bulk packaging design types other than bags must be subjected to a stacking test. The duration of the stacking test must be for 24 hours, except for plastic drums, jerricans, and composite packaging 6HH intended for liquids. These packagings intended for liquids must be subjected to a stacking test for a period of 28 days. When using a combination packaging where the outer packaging is a plastic drum or jerrican and the inner packaging is intended for liquids, the plastic drum or jerrican would be subject to the 24-hour stacking test, not the 28-day requirement (See § 178.606(c)(1)).

For the purposes of periodic retesting, the stacking test may be done in accordance with § 178.606(c)(1) or, as an alternative, the packaging design may be tested using a dynamic compression testing machine as described under § 178.606(c)(2)(ii). The dynamic compression testing machine is only authorized for periodic retesting and may not be used when performing design qualification testing on a new packaging design type (e.g., "a different packaging" as defined under § 178.601(c)(4)).

Provided your non-bulk packagings, other than bags, have been subjected to the design type tests and periodic retests applicable to stacking requirements, you may stack your products in the manner provided in your examples.

I hope this information is helpful. If we can be of further assistance, please contact us.

Sincerely yours,

Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

178.606, 178.601

Regulation Sections

Section Subject
178.601 General requirements
178.606 Stacking test