Interpretation Response #06-0263 ([Packaging Technology Center] [Mr. Thomas Schneider])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Packaging Technology Center
Individual Name: Mr. Thomas Schneider
Location State: TX Country: US
View the Interpretation Document
Response text:
Mar 20, 2007
Mr. Thomas Schneider Reference No. 06-0263
President
Packaging Technology Center
P.O. Box 15274
Houston, Texas 77220
Dear Mr. Schneider:
This is in response to your November 15, 2006 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packagings for air bag modules. Specifically, you ask if shrink wrapping 11 fiberboard boxes of air bag modules to a pallet constitutes a single packaging under the HMR. According to your letter, each box measures 96” Lx 41” W x 4” and the palletized unit measures 96” Lx 41” W x 48”. Also, you indicate that a representative of tie Department suggested that if a shroud were placed over the palletized unit, it may meet the criteria for a 50G design.
Authorized packagings for air bag modules are provided in § 173.166(e). The palletized configuration described in you letter is not an acceptable packaging for air bag modules. A 4G box that meets the general packaging requirements in Part 173 and the performance oriented packaging requirements in Part 178 at the Packing Group III performance level is an authorized packaging. To utilize the packaging configuration described in your letter, the individual boxes must be authorized 4G packagings and the shrink wrapped a11et must be treated as an overpack in accordance with § 173.25. A 50G packaging is not in authorized packaging for air bag modules.
I hope this information is helpful. Please contact us if you require additional ass stance.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
173.166(e)
Regulation Sections
| Section | Subject |
|---|---|
| 173.166 | Safety devices |