PHMSA Response Letter

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October 1, 2009

Mr. Randy Hill
Chemtran Services USA, Inc.
P.O. Box 62456
Houston, TX 77205-2456

Ref. No.: 09-0176

Dear Mr. Hill:

This responds to your July 23, 2009 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the testing of specification packagings. According to your letter, you successfully completed testing a UN 4GV combination package using a 1 gallon fragile glass jug as an inner packaging and vermiculite cushioning and absorbent material. You ask if you can replace the vermiculite absorbent material with polystyrene absorbent sheet pads and replace the vermiculite used to suspend the inner packaging inside the fiberboard outer packaging with a fiberboard sleeve without retesting the completed package.

The answer is no. The substitution of a different absorbent material and a different means of suspending the inner packaging inside of the outer packaging constitutes a new packaging design. Each new packaging design is subject to design qualification testing under Part 178, Subpart M.

I trust this satisfies your inquiry. If we can be of further assistance, please contact us.

Sincerely,

Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards

178 Subpart M