The Journal ofHazMat Transportation's? Exclusive Comments on Current U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations

摘要

This letter provides some useful information for those responsible for qualifying packages. It may reduce company package testing costs somewhat. The questioner is using the excepted quantity provisions in §§173.4 and 173.4a. Packages shipped under these provisions must be "capable" of withstanding drop tests (see for example §173.4(a)(6)(i)). Because, regulators always had a problem with shippers simply proclaiming their packages as "capable" of meeting the drop tests, recent changes added the words as "demonstrated by prototype testing". That text in itself suggests some flexibility in testing variations - probably testing a worst case packaging will suffice for demonstrating a range of similar packagings.