Interpretation Response #08-0310 ([SFB Plastic, Inc.] [Mr. John Fosse])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: SFB Plastic, Inc.
Individual Name: Mr. John Fosse
Location State: KS Country: US
View the Interpretation Document
Response text:
February 4, 2009
Mr. John Fosse
Vice President-Sales
1819 W. Harry Street
Wichita, KS 67213
Ref. No. 08-0310
Dear Mr. Fosse:
This responds to your November 20, 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you are required to have separate packaging test records and separate report identification numbers for combination packagings that are identical (i.e., the same inner packagings, the same outer packaging and the same packaging configuration) except for closure method (e.g., one is closed using 2-inch tape while another is closed using glue).
The answer is no. You are required to maintain a record of each design qualification test in accordance with § 178.601(l). The test record must include a description of the packaging design type, including methods of closure. You may maintain a single test record and test report identification number for identical packagings that differ only in method of closure, provided each method of closure is documented in the test report and the packaging successfully passes the required tests when closed in accordance with each closure method identified in the test report.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
178.601(1)
Regulation Sections
| Section | Subject |
|---|---|
| 178.601 | General requirements |