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| Comments on Section 178.2 |
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Do the Notification Requirements Described in §178.2(c) of the HMR Apply to DOT Specification Cylinders?
Section 178.2; letter dated January 08, 2007 [sic], to Mr. Kevin M. Greene, E.I. DuPont de Nemours & Co. Is a written “notification” as described in § 178.2(c) of the HMR required to be provided by the manufacturer or subsequent distributor of a DOT specification cylinder to each person to whom such packaging is transferred? This letter confirms that the answer to that question is “no” - at least as far as the specific requirement in § 178.2(c)(1)(i) is concerned. This paragraph requires that the manufacturer or distributor provide written notification to persons to whom a packing is transferred “of all requirements of this part [178] not met at the time of transfer”. The requirement does not apply in the case of a DOT specification cylinder because all Part 178 requirements are met by the cylinder manufacturer at the time of manufacture and prior to transfer. This is unlike the case for most other DOT specification, and all UN standard packagings. For these packagings the specifications and/or applicable packaging performance standards normally address the manner of closure and the closures to be employed. When these types of packagings are transferred, it is necessary for the manufacturer or distributor to notify the user of the packaging as to how the packaging must be completed and closed to conform to the specification. In the case of UN standard packagings, this is the manner in which the packaging was configured and closed when the design qualification tests were performed. This article, in its entirety, is archived in HAZMAT Packager & Shipper's HazMat Database, an optional feature to subscribers. Information on obtaining a subscription to HAZMAT Packager & Shipper and its associated features can be found here. |
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