Interpretation Response #14-0194 ([S.C. Johnson & Son, Inc.] [Mr. Chris Kubicek])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: S.C. Johnson & Son, Inc.
Individual Name: Mr. Chris Kubicek
Location State: WI Country: US
View the Interpretation Document
Response text:
March 13, 2015
Mr. Chris Kubicek
S.C. Johnson & Son, Inc.
1525 Howe Street – MS 042
Racine, WI 53403
Ref. No. 14-0194
Dear Mr. Kubicek:
This responds to your October 14, 2014 email requesting clarification on the design qualification requirements for DOT-2S containers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that some manufacturers of 2S containers interpret that the drop test must be performed on a filled container with only the valve cup installed - reflecting the product configuration of the container during the manufacturing process immediately after filling. Additionally, you attached photographs of examples of the containers with the valve only configurations and with the actuator overcap configuration. Specifically, you ask that when the container (i.e., the aerosol) is drop tested in accordance with § 178.33b-7, should the test be conducted with the actuator overcap removed or should the container be tested in its assembled configuration for consumer use?
The container should not be tested in its assembled configuration. The drop test must be performed with the valve only, i.e., without any covers/overcaps attached.
I hope this answers your inquiry. If you need additional assistance, please contact this Office at 202-366-8553.
Sincerely,
Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
178.33b-7,
Regulation Sections
| Section | Subject |
|---|---|
| 178.33b-7 | Design qualification test |