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Interpretation Response #99-0270 ([Sperry-Sun Drilling Services] [Mr. Jack E. Gilbert, Jr.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sperry-Sun Drilling Services

Individual Name: Mr. Jack E. Gilbert, Jr.

Location State: LA Country: US

View the Interpretation Document

Response text:

March 15, 2000


Mr. Jack E. Gilbert, Jr.              Ref. No. 99-0270
Sperry-Sun Drilling Services
4607 Highway 90 East
Broussard, LA 70518

Dear Mr. Gilbert:

This is in response to your letter dated September 21,1999, requesting clarification on the packaging requirements for gas samples under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 ­180).  Specifically, you ask whether shipping gas samples in bags placed in an open top can such as a coffee can or paint can with a friction lid sealed with plastic-ring seals is permissible under the HMR.

Section 173.306(a)(4)(iii) requires that non-pressurized gases, flammable be packed in hermetically sealed glass or metal inner packagings of not more than 2.5 L (0.5 gallons) overpacked in a strong outer packaging.  You have proposed to place the gas sample in a plastic bag which is enclosed in a one gallon round metal can closed with a friction lid and a HAZLOC ring lock.

You have provided no information to show that your proposed packaging meets the definition of hermetically sealed in § 171.8. If you determine that a 2.5 L (0.5 gallon) metal can closed with a friction lid and a HAZLOC ring lock meets the definition of hermetically sealed, it can be used as an inner packaging as specified in § 173.306 (a)(4)(iii).  The use of a one gallon metal can will require an exemption from the HMR.  Exemption application procedures and requirements are provided in § 107.105 of the HMR.

I hope this answers your inquiry.



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


Regulation Sections

Section Subject
173.22 Shipper's responsibility