On June 14th, 2000, DOT held a Third Party Testing Seminar in Chicago to field questions about upcoming issues relating to packaging. Summarizing the issues relating to UN certified steel containers, the following points were discussed. With regard to the adoption of ISO Guide 25, if it were adopted it would be proposed that it would be incorporated in to the UN text. The opinion of the panel was that even if it were incorporated into the text and the US put it into CFR 49, they do not want to change the ability to self certify. Regarding Vibration testing, if it were incorporated into CFR, the audience questioned whether the requirement stating that "the container must be capable of passing" rather than "the container must pass" would still exist. DOT said that they would adopt it if it became part of the text although whether it would be just a design type requirement or whether it would also apply to the periodic re-test would be something that they would have to look at if the situation ever arose. Periodic Re-testing was discussed from the perspective of if there was any chance of getting rid of the requirement to perform the re-test every year. DOT stated that "maybe" if we can come up with a reasonable solution. DOT offered to discuss it as they accept that the current situation is far from perfect. The Closure Instructions issue was discussed and one reference to torque was made suggesting that "minimum" torque measurements be stated on the instruction rather than stating a torque range. DOT agreed with this option. Relative to required drum markings (CFR 178.503(a)) on the issue of "intent to recondition," for the first time DOT offered a definition of the phrase "liable to undergo a reconditioning process" and used the example of a packaging that meets minimum thickness requirements. Until now, DOT only defined this intent in a provision referencing drums over 30 gal capacity.
DOT/UN