Interpretation Response #11-0158 ([Corrosion Testing Laboratories, Inc.] [Mr. Bradley D. Krantz])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Corrosion Testing Laboratories, Inc.
Individual Name: Mr. Bradley D. Krantz
Location State: DE Country: US
View the Interpretation Document
Response text:
April 23, 2012
Mr. Bradley D. Krantz
V.P. of Laboratory Services
Corrosion Testing Laboratories, Inc.
60 Blue Hen Drive
Newark, DE 19713
Ref. No. 11-0158
Dear Mr. Krantz:
This responds to your June 28, 2011 request for clarification on § 173.137(c)(2) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you are to use only the corrosion rate criterion stated in § 173.137 for determining metal corrosivity or are you to use both the corrosion rate and the localized corrosion rate criteria of the UN Method.
You may use the UN Manual of Tests and Criteria or other equivalent methods. In a final rule published December 20, 2004 under Docket HM-215G (69 FR 76155), we revised the language in § 173.137 (c)(2) mandating the corrosion test in the UN Manual of Tests and Criteria as the only acceptable test method for determining the corrosivity of a material. That was not our intent. In a final rule published December 29, 2006 under Docket HM-215I (71 FR 78596), we revised the language in § 173.137(c)(2) to specify that corrosivity may be determined in accordance with methods described in the UN Manual of Tests and Criteria, as well as other equivalent methods, such as those described in ASTM G 31-72.
I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
173.137
Regulation Sections
| Section | Subject |
|---|---|
| 173.137 | Class 8-Assignment of packing group |