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Interpretation Response #99-0254 ([Russell-Stanley] [Mr. Earl V. Lind])

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

Interpretation Response Details

Response Publish Date:

Company Name: Russell-Stanley

Individual Name: Mr. Earl V. Lind

Location State: NJ Country: US

View the Interpretation Document

Response text:

July 28, 2000


Mr. Earl V. Lind                             Ref. No. 99-0254
655 Route 202/206
Bridgewater, NJ 08807-1762

Dear Mr. Lind:

This is in response to your letter asking whether a UN 3H1 packaging tested under an original design qualification without a “node” is a different design if the packaging is manufactured with a  “node”.  I apologize for the delay in responding and hope it has not caused any inconvenience.

You provided the following scenario:

A change would be made to a UN 3H1 packaging that differs in only a minor respect from the original qualified design.  This change would add a small “node” to the top of the container that can be punctured to allow easy emptying of the contents.  The customer would be notified at the time of transfer that once the packaging had been punctured to empty the contents, the packaging would no longer be usable for hazardous materials, in effect making it a single use packaging.  Except for the 28-day stacking test, design qualification testing has been successfully completed.  A stack test was conducted during the periodic retest.  The packaging replaces a previous UN I HI drum incorporating the puncture vent feature that has been discontinued.

A different packaging is one that differs (i.e., not identical) from a previously produced packaging in structural design, size, material of construction, wall thickness, or manner of construction.  A change in a component of a packaging which differ from the original design is a “different”  packaging as defined in § 178.601 (c)(4).  The “UN 3H1"  packaging, incorporating the puncture vent feature (i.e., node) for emptying, is a different design type Such packaging tested without a “node” will not qualify a packaging with a “node” or nodule.

Before a packaging goes into production  the design must be certified through performance of the design qualification tests prescribed in § 178.601 (c)(1).  A packaging may not be certified and marked as meeting a UN standard unless it has passed all design qualification tests, including the stacking test.  The periodic retests is a quality control measure for newly manufactured packagings, and during
subsequent production of packagings of that design, periodic retests must be performed at least once every twelve months for single packaging, such as a  “UN 3H1"  non-removable head jerrican (see § 178.601(e)).

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us



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


Regulation Sections

Section Subject
178.601 General requirements