Interpretation Response #98-0213 ([International Fibre Drum Institute] [Mr. Gordon Rousseau])

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

Interpretation Response Details

Response Publish Date: 08/27/1998

Company Name: International Fibre Drum Institute

Individual Name: Mr. Gordon Rousseau

Location State: DC Country: US

View the Interpretation Document

Response text:

AUG 27, 1998

Mr. Gordon Rousseau                        Ref. No. 98-0213
International Fibre Drum Institute
1850 K Street, N.W., Suite 200
Washington, DC 20006-3511

Dear Mr. Rousseau:

This is in response to your letter dated July 24, 1998, regarding the gross mass marking on packagings that are shorter than their original design type. Specifically, you ask if it is proper to mark a packaging that is shorter than its original design type with the gross mass of the tested design type under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Section 178.601(c) (4) provides that packagings "which differ from the design type only in their lesser design height" are not, by definition, different packagings. Section 178.503(a) (4) states that a packaging must be marked with a "designation of the specific gravity or mass for which the packaging design type has been tested ... " There is no requirement in the HMR to reduce the gross mass marking on shorter packagings because of a reduction in design height. Therefore, it is proper to mark shorter packagings with the gross mass marking of the tested design type.

I hope this satisfies your request.

Sincerely,

Edward T. Mazzullo
Director, Office of Hazardous Materials Standards

178.601

Regulation Sections