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Interpretation Response #17-0028

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

Interpretation Response Details

Response Publish Date: 05-25-2017
Company Name: Ball Food Aersol    Individual Name: Mr. John Blum
Location state: CO    Country: US

View the Interpretation Document

Response text:

May 25, 2017

John J. Blum
Director, Technical Services
Ball Food & Aerosol
9343 W. 108th Circle
Westminster, CO 80021

Reference No. 17-0028

Dear Mr. Blum:

This letter is in response to your March 21, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the wall thickness of Department of Transportation (DOT) Specification 2P and 2Q inner non-refillable metal receptacles.

We have paraphrased and answered your questions as follows:

Q1. You ask how wall thickness is defined and if it denotes the thickness of the steel substrate or the combined thickness of the steel and any applied polymeric liners.

A1. Wall thickness is the thickness of the material as specified in §§ 178.33 5 and 178.33a-5 for DOT Specification 2P and 2Q containers, respectively. This does not include any applied polymeric liners that may be added.

Q2. You ask if and/or when rounding up the wall thickness measurement is allowed. You further provide an example asking if a wall thickness measured at 0.0066 inch meets the 0.007-inch requirement for DOT Specification 2P containers.

A2. Section 178.33-7 states, "The minimum wall thickness for any container shall be 0.007 inch." Therefore, rounding up is not acceptable as the wall thickness would not meet the minimum requirement.

I hope this information is helpful. Please contact us if we can be of further assistance.



T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

178.33-5, 178.33a-5, 178.33-7

Regulation Sections

Section Subject
§ 178.33-7 Wall thickness