Interpretation Response #02-0180 ([AAPER Alcohol] [Linda Whitton])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: AAPER Alcohol
Individual Name: Linda Whitton
Location State: KY Country: US
View the Interpretation Document
Response text:
Aug 27, 2002
Ms. Linda Whitton Reference No. 02-0180
Traffic Manager
AAPER Alcohol
P.O. Box 339
Shelbyville, KY 40066-0339
Dear Ms. Whitton:
This is in response to your June 12, 2002 letter, requesting an opinion of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements and standards for cartons. Specifically, you state your company ships Ethyl Alcohol, Class 3 (flammable liquid) in corrugated rectangular cartons and uses corrugated inserts to cover the open area of the inner flaps of your pint cartons. You question if corrugated inserts are a requirement of the HMR. You further indicate your intention to submit the cartons for re-certification without the corrugated inserts provided they are not required.
Based on the information you provided, this Office can not determine if corrugated inserts are necessary to obtain re-certification of your cartons. Non-bulk Performance-Oriented Packaging Standards are found in Subpart L of Part 178. The testing requirements are found in Subpart M of Part 178.
Based on the information in your letter, it appears that your material can be shipped as a limited quantity. Section 173.150 states that limited quantities of Class 3 (flammable liquids) may be packaged in non-specification combination packagings that conform to the general packaging requirements of subpart B of Part 173 and may not exceed 30 kg gross weight (66 pounds). Flarrunable liquids in Packing Group II must be packaged in inner packaging not over 1.0 L (0.3 gallon) net capacity each, packed in strong outer containers not to exceed 30 kg gross weight (66 pounds). Flammable liquids in Packing Group III must be packaged in inner packagings not over 5.0 L (1.3 gallons) net capacity each, packed in strong outer packagings not to exceed 30 kg gross weight (66 pounds).
As defined in § 171.8, a strong outer container is the outermost enclosure which provides protection against the unintentional release of its contents under conditions normally incident to transportation.
Strong outer containers that are non-specification packagings do not have to be tested in accordance with the performance test requirements specified in Part 178. However, these packagings must conform to the general packaging requirements in § 173.24.
I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
173.202