Interpretation Response #12-0120 ([Greif, Inc., Rigid Industrial Packaging & Services, North America] [Mr. Jordan J. Brodsky])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Greif, Inc., Rigid Industrial Packaging & Services, North America
Individual Name: Mr. Jordan J. Brodsky
Location State: OH Country: US
View the Interpretation Document
Response text:
July 18, 2012
Mr. Jordan J. Brodsky
Director of Product Technical and Regulatory Support
Greif, Inc.
Rigid Industrial Packaging & Services, North America
366 Greif Parkway
Delaware, OH 43015
Ref. No. 12-0120
Dear Mr. Brodsky:
This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the testing of non-bulk packagings. In your letter, you interpret a pass/fail criterion at § 178.606(d)
that would allow a drum successfully withstanding the stacking test to then be leakproofness tested in accordance with
§ 178.604. You ask whether the steel drum test samples used for the stacking test as prescribed in § 178.606 may also be used for the leakproofness test as prescribed in § 178.604.
The answer is no. However, in accordance with § 178.601(k), several tests may be performed on a single sample with the approval of the Associate Administrator and provided the validity of the test results is not affected. You may apply for approval to perform several tests on a single sample under the procedures specified in 49 CFR § 107.705.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
178.601
Regulation Sections
| Section | Subject |
|---|---|
| 178.601 | General requirements |