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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.







T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division



Regulation Sections

Section Subject
178.601 General requirements