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Comments on Sections 173.22 and 178.2 |
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By Andy Altemos, Senior Technical Advisor September, 2007
Closing of Hazardous Materials Packages
Sections 173.22 and 178.2;
letter dated July 8 2007,
to Ms. Randylynn Bourassa,
Dupont Automotive Systems
To put this DOT letter in context, it is noted that in the question posed to DOT the questioner advised that removable (open) head drums are received from the drum manufacturer, but are filled with liquids by removing only the “small bung” in the top head of the drum. As stated in the letter, the question was asked whether it is necessary to remove the top heads from the drum, which are “installed and torqued by the manufacturer”, and to reclose them in accordance with the manufacturer’s closure notification provided with the drums.
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