Interpretation Response #08-0089 ([3M Package Engineering, 3M Sourcing Operations] [Mr. William Gramer Specialist])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: 3M Package Engineering, 3M Sourcing Operations
Individual Name: Mr. William Gramer Specialist
Location State: MN Country: US
View the Interpretation Document
Response text:
July 31, 2008
Mr. William Gramer
Specialist, 3M Package Engineering
3M Sourcing Operations
3M Center 216-02N-08
St. Paul, MN 55144-1000
Ref. No. 08-0089
Dear Mr. Gramer:
This responds to your March 26, 2008 letter requesting clarification of the second sentence of "Note 2" in Explosive Package Instruction 115 in §173.62 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180.) Specifically, you request clarification or confirmation of your understanding of this requirement in the HMR.
In Packing Method 115, the second sentence states that a composite package consisting of a plastic receptacle in a metal drum (6HA1) may be used in lieu of combination packaging. This means that a composite UN 6HA1 plastic inner receptacle within an outer metal package may be shipped as a PG II certified single package in lieu of a combination package. A Class 1 material appropriately packaged in accordance with Packing Method 115, Note 2, in a composite package 6HA1 does not require additional outer packaging or absorbent material specified for other liquid explosives covered and packaged in combination packagings according to Note 1.
I hope this answers your inquiry.
Sincerely,
Susan Gorsky
Acting Chief, Standards Development
Office of Hazardous Materials Standards
173.62 Packing Instruction 115
Regulation Sections
| Section | Subject |
|---|---|
| 173.62 | Specific packaging requirements for explosives |