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Interpretation Response #13-0209 ([DuPont Global Logistics] [Mr. Kevin Greene])

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

Interpretation Response Details

Response Publish Date:

Company Name: DuPont Global Logistics

Individual Name: Mr. Kevin Greene

Location State: AL Country: US

View the Interpretation Document

Response text:

February 10, 2014

Mr. Kevin Greene
Hazardous Materials Consultant
DuPont Global Logistics
P.O. Box 525
Axis, AL 36505

Reference No.: 13-0209

Dear Mr. Greene:

This is in response to your November 5, 2013 letter and conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if the HMR authorize the installation of a 2 inch bung/vent into a UN 1H1 plastic drum that would permit air to enter the drum, but not allow the release of hazardous material from the drum.  You note that the drum will be fitted with the bung/vent prior to subjecting it to the tests specified in Part 178.

The HMR authorize openings for filling, emptying or venting in UN 1H1 plastic drums in accordance with the provisions of § 173.24(g).  Please note that except for shipments of cryogenic liquids as specified in §173.320(c) and of carbon dioxide, solid (dry ice), venting of packages is not permitted when transportation by aircraft is involved.  When venting is authorized, provided the drum passes the appropriate design tests with the bung/vent in place and does not allow the escape of hazardous material, the opening described in your letter is acceptable.  

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.24(g), 173.320(c)

Regulation Sections

Section Subject
173.24 General requirements for packagings and packages
173.320 Cryogenic liquids; exceptions