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Interpretation Response #14-0048

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

Interpretation Response Details

Response Publish Date: 06-10-2014
Company Name: HMT Associates, L.L.C.    Individual Name: Mr. E.A. Altemos
Location state: NM    Country: US

View the Interpretation Document

Response text:

June 10, 2014

Mr. E.A. Altemos
HMT Associates, L.L.C.
603 King Street
Suite 300
Alexandria, VA   22314
Ref. No. 14-0048

Dear Mr. Altemos:

This responds to your March 13, 2014 request for clarification of packaging specifications under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180.)   Specifically, you ask if a 6HA1 composite packaging design may include a small hole, known as a weep hole, in the outer protective steel drum.   

It is your understanding that although § 178.504 contains requirements regarding closures, the        use of weep holes in the outer protective steel drum of a composite packaging is not prohibited in the HMR.   Your understanding is that requirements for closures apply to openings in the heads or body of a drum, and do not prohibit a small (usually several millimeters diameter) weep hole not fitted with a closure conforming to the closure provisions in § 178.504(b).  You also state that weep holes are widely used in composite packaging for two reasons: (1) to allow drainage of moisture or condensation between the inner receptacle and outer protective drum to minimize possibility of internal corrosion that could compromise the packaging; (2) to allow the escape of air from the outer packaging during insertion of the snugly fitting inner receptacle.      

Your understanding is correct.  The HMR do not prohibit the use of small weep holes in the outer packaging of a composite packaging (6HA1) if they are part of the original design.  The packaging must meet the general packaging requirements in § 173.24, the specification packaging requirements for 6HA1 in § 178.522, and the tested design type of the packaging must have included the weep hole.

I hope this answers your inquiry.  If you need additional assistance, please contact this office at (202) 366-8553.

Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

178.504, 178.504(b), 173.24, 178.522


Regulation Sections

Section Subject
§ 178.504 Standards for steel drums