Drop Testing for Steel Drums
Pipeline and Hazardous Materials Safety Administration · Oct 22, 1999 · Reference No. 99-0264
Reggie’s quick take
A testing center asked whether it could run the second drop test on steel drums by hitting three different spots on the drum, using one sample for each spot. PHMSA says no. The rule in § 178.603(a) calls for three samples in the second drop, aimed at the weakest part of the drum not hit in the first drop. PHMSA also says this method is not an equivalent test, so it cannot be approved as an alternate under § 178.601(h).
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 letter dated September 20, 1999, requesting an approval of an alternate drop test procedure for steel drums and a clarification of these requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
During a recent inspection, Riviana Foods, Inc.'s Packaging Testing Center (Riviana), a third party testing agency, was cited with a probable violation of the drop test procedures specified in § § 178.601 (f) and 178.603(a). The probable violation was issued because of failure to perform drop tests using the minimum number of samples and failure to perform drop tests on the weakest part of the drum not tested by the first drop. Specifically, Riviana performed the second drop test on three different parts of a drum, using only one drum for each of the three separate drops.
The provisions of § 178.603(a) require that two separate drop tests be performed. The first drop test, using three samples, must strike the target diagonally on the chime or, if the packaging has no chime, on a circumferential seam or edge. The second drop test, also using three samples, must strike the weakest part of the drum not tested by the first drop.
The second drop test procedure used by Riviana, i.e., performing the second drop test on three separate parts of the drum using one sample each, does not comply with the requirements in § 178.603(a). Additionally, this procedure is not equivalent to that prescribed by the regulations and, therefore, is not eligible for approval as an equivalent packaging under 49 CFR 178.601(h).
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.