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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #15-0038 ([Hazardous Materials Consultant] [Mr. Mark B. Hawk])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazardous Materials Consultant

Individual Name: Mr. Mark B. Hawk

Location State: TN Country: US

View the Interpretation Document

Response text:

May 5, 2015

Mr. Mark B. Hawk
Hazardous Materials Consultant
49 Palisades Parkway
Oak Ridge, TN 37830

Reference No. 15-0038

Dear Mr. Hawk:

This is in response to your July 16, 2014 e-mail and attached letter, forwarded to the Standards and Rulemaking Division on February 25, 2015, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning use of a Department of Transportation (DOT) Specification 7A, Type A container with a package mass less than the qualified package mass of the container. We have paraphrased your questions and answered them in the order you provided.

Q1. Can a DOT Specification 7A, Type A container that has been qualified to a package mass equal to or greater than 5,000 kilograms (11,000 pounds) but less than 10,000 kilograms (22,000 pounds) be used for a shipment having a package mass less than 5,000 kilograms (11,000 pounds) without any additional testing or demonstration of compliance per § 173.461?

A1. The answer is no. The package described in your scenario cannot be used without additional testing or demonstration of compliance. The Type A packaging tests specified in § 173.465 require a free drop distance of 0.9 meters (3 feet) for packages with a mass between 5,000 and 10,000 kilograms; for packages under 5,000 kilograms, the free drop distance specified in § 173.465 is 1.2 meters (4 feet). Thus, a package which has been qualified for the greater mass (and lower drop distance) would need to be re-qualified for the lesser mass (and higher drop distance) per the requirements in § 173.465. The impacts of any other changes in the properties of the contents would also need to be assessed against the requirements of § 173.465.

Q2. If any additional demonstration of compliance is required, please specify what testing and/or documentation is required.

A2. Testing, or other demonstration of compliance in accordance with § 173.461, must be done to show the package meets the requirements of § 173.465. The testing or other demonstration of compliance must be documented in accordance with the requirements of § 173.415(a).

I hope this satisfies your request.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.46, 173.465

Regulation Sections

Section Subject
173.465 Type A packaging tests