Interpretation Response #98-0336 ([Ms. Britt-Marie Butler])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Ms. Britt-Marie Butler
Country: SE
View the Interpretation Document
Response text:
JAN 14, 1999
Ms. Britt-Marie Butler Reference No. 98-0336
Husqvarna AB
S-433 81 Jonsered SWEDEN
Dear Ms. Butler:
This is in response to your letter asking if your packaging, a 6-liter UN 3H1 non-removable head plastic jerrican pin-mounted (joined) to a non-specification 2.5 liter plastic blow-molded bottle, would qualify as a combination packaging in the United States.
The answer is no. As defined in 49 CFR 171.8, a combination packaging means one or more inner packagings secured in a non-bulk outer packaging; a condition your joined packagings do not meet. Instead, your jerrican meets the definition in § 171.8 for a single packaging and must be tested and approved in accordance with the UN specification requirements. Because the packagings are pin-mounted, we also recommend that they be drop tested separately and after being joined together.
I hope this satisfies your request.
Sincerely,
Edward T. Mazzullo Director,
Office of Hazardous Materials Standards
178.509, 171.8