Interpretation Response #18-0008
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Reference No. 18-0008
Dear Mr. Martin:
This letter is in response to your January 10, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a manufacturer’s dual marking of containers. Specifically, you ask whether it is permissible for a container to be dual marked as both a United Nations specification 1A1 (UN 1A1) non-removable head steel drum and either a Department of Transportation specification 2Q (DOT 2Q) inner, non-refillable metal receptacle.
The answer is yes, provided that the packaging meets the design and testing standard in the HMR for both package specifications, in all aspects. For example, the 1 liter (L) maximum capacity specified for DOT 2Q containers is smaller than the 450 L maximum capacity specified for UN 1A1 drums (see §§ 178.33a-2 and 178.504, respectively). Therefore, a dual marked UN 1A1 drum and DOT 2Q container could not exceed 1 L capacity. The requirements for DOT 2Q design and testing are specified in Part 178 Subpart B. The requirements for UN 1A1 drum design and testing are specified in Part 178 Subparts L and M.
I hope this information is helpful. Please contact us if we can be of further assistance.
|§ 178.504||Standards for steel drums|