Compatibility test reports
Pipeline and Hazardous Materials Safety Administration · Aug 20, 1993 · Reference No. 93-0201
Interprets: 49 CFR § 173.24, 49 CFR § 178.603
Reggie’s quick take
A company asked whether it must keep compatibility test reports for corrosive materials shipped in polyethylene packagings. The company had been cited for not having those reports under § 173.24(e). PHMSA's answer is that plastic packagings for liquid hazardous materials must withstand the Appendix B compatibility test, or an alternative procedure approved by the Associate Administrator. That test is required for all packagings holding Packing Group I liquids. For Packing Group II and III liquids, the packaging may instead show it can withstand the test through past handling and transport experience, design specifications, or the cold drop test in § 178.603(c).
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your November 24, 1992, letter concerning the availability of compatibility test data prescribed under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You stated in your letter that Mr. Thomas Lynch of the Office of Hazardous Materials Enforcement, Eastern Region, cited your company for a probable violation of 49 CFR l73.24(e) for not having available compatibility test reports for various corrosive materials being shipped in polyethylene packagings and receptacles.
Paragraph 173.24(e)(3) requires that plastic packagings used for liquid hazardous materials be capable of withstanding without failure the procedure specified in Appendix B of Part 173 or an alternative procedure specifically approved by the Associate Administrator for Hazardous Materials Safety. The procedure must be performed on all packagings used to transport liquid hazardous materials in Packing' Group I. However, for Packing Group II and III materials, capability to withstand the Appendix B compatibility test can be demonstrated by previous handling and transportation experience, design specifications, or by the cold drop test specified in § l78.603(c).
I hope this information is helpful. Please contact this office if you require additional assistance.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.