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Responsibility § 173.22

It is the responsibility of the packager/shipper, not the container manufacturer, to determine the proper package specification for each lading. The shipper determines that the drum is authorized, assembled and marked for packaging. The shipper may request a certificate of compliance from the manufacturer to demonstrate that each container conforms with the performance testing provisions in §178.600.

Since the test for the old specification testing and the new performance standard testing are not the same, it is necessary to perform complete testing for each marking appearing on the container. Some container specifications that have been used for years may become obsolete under the new performance standard testing requirements. There is no conversion chart to look up the equivalent UN marking for a DOT-17E.

 

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