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Interpretation Response #98-0594

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

Interpretation Response Details

Response Publish Date: 06-04-1998
Company Name: Greif Bros. Corporation    Individual Name: Mr. Joseph Grebe
Location state: OH    Country: US

View the Interpretation Document

Response text:

JUN 4, 1998


Mr. Joseph Grebe
Manager, Testing and Technical Service
Greif Bros. Corporation
120 I-A South Houk Road
Delaware, Ohio 43015

Dear Mr. Grebe:

This is in response to your letter dated March 20, 1998, regarding the package marking requirements in 49 CFR 178.503(a)(4)(ii) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask us to define the terms "net mass" and "gross mass."

The term gross mass is defined in § 171.8 as "the weight of a packaging plus the weight of its contents." The term "net mass" means the weight of the contents in a packaging. The difference between the two terms is the fact that you include the weight of the packaging in determining its gross mass but you do not include the.weight of the packaging when determining its net mass. Therefore, a steel open head drum that weighs 35 kilograms and has a maximum net mass of 400 kilograms would be correctly marked as "IA2/X435/S ... t1 in accordance with § 178.503(a)(4)(ii).

I hope this satisfies your request.



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

Regulation Sections

Section Subject
§ 178.503 Marking of packagings