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Interpretation Response #98-0589 ([Ten-E Packaging Services, Inc.] [Mr. Robert J. Ten Eyck])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ten-E Packaging Services, Inc.

Individual Name: Mr. Robert J. Ten Eyck

Location State: MN Country: US

View the Interpretation Document

Response text:

JAN 29, 1998


Mr. Robert J. Ten Eyck
Director, Technical Services
Ten-E Packaging Services, Inc.
1666 County Road 74
Newport, Minnesota 55055

Dear Mr. Ten Eyck:

This is in response to your letter of October 9, 1997, requesting clarification on the requirements for testing packagings under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically you ask whether a UN 3H1 drum which was tested and certified with one 2" buttress threaded plastic plug and one 2" NPS threaded plastic plug may be changed to two 2" buttress threaded plastic plugs without further testing of the packaging.

The answer is yes. The original test was performed with one of each of the closures (i.e., one buttress and one NPS). The closures may then be changed to two buttress or two NPS without further testing.

I hope this information is helpful.



Delmer F. Billings
Chief, Regulations Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.601 General requirements