Packaging Solid Materials in Single Packagings Tested for Liquids

摘要

A reader submits the following scenario and questions concerning the use of drums tested for liquids as packagings for solids: A customer would like to utilize provisions in 173.24a(b)(3) allowing a solid filling materia! with a packaging designed and tested for liquids. After plugging in the mini hers we determined that a Y 1.8 drum could he filled to a gross mass of 1,100 Ihs. Seems simple enough, hut the definition of a non-bulk packaging is one that does not exceed 882 Ihs. However, the definition also includes the conjunction "and", which is just confusing. Need some help with this one. Can a 55 gallon drum used for solids, with a gross mass of 1,100 lbs., still be considered non-bulk by applying the current definition of bulk / non-bulk from 171.8?