Interpretation Response #04-0170 ([Packaging Corporation of America] [Mr. Michael Gilgenbach])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 10/22/2004

Company Name: Packaging Corporation of America

Individual Name: Mr. Michael Gilgenbach

Location State: IL Country: US

View the Interpretation Document

Response text:

Oct 22, 2004

Mr. Michael Gilgenbach                Reference No. 04-0170

Packaging Corporation of America
Technical and Development Center
2150 South Shaddle Avenue
Mundelein, IL 60060

Dear Mr. Gilgenbach:

This responds to your July 13, 2004 letter requesting clarification on the proper use of a package manufacturer’s symbol or “M” number when marking UN specification packagings under 178.503(a)of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180). Specifically, you ask whether your company, which produces corrugated boxes, an approval agency certifying compliance (e.g., third party testing facility), or a customer is required to have a symbol or “M” number.

If your company does not accept responsibility for certifying a packaging and provides packagings to your customer who does accept responsibility for certifying the packaging, your company does not need an “M” number.

I hope this answers your inquiry.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

178.3, 178.503

Regulation Sections