Interpretation Response #03-0094 ([Inland Paperboard and Packaging, Inc.] [Ms. Nadine Helm])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 10/22/2004

Company Name: Inland Paperboard and Packaging, Inc.

Individual Name: Ms. Nadine Helm

Location State: PA Country: US

View the Interpretation Document

Response text:

Oct 22, 2004

Ms. Nadine Helm
                Reference No. 03-0094
Office Manager
Inland Paperboard and Packaging, Inc.
136 East York Street
Biglerville, PA 17307

Dear Ms. Helm:

This is in response to a request from Ms. Sally Banks of your company concerning the recordkeeping requirements contained in § 178.60 1(1) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). She asked if the fiberboard box manufacturer or the facility that packages the hazardous material is required to retain the test report certifying that a knocked- down, unassembled UN 4G fiberboard box meets the performance test requirements in 49 CFR Part 178, Subpart M. Your company manufactures the box and prints the UN certification mark on the box on behalf of your customer, the UN standard package assembling facility, who performs and certifies the test results for the completed hazardous materials packagings. We apologize for the delay in responding and any inconvenience it may have caused.

Under the HMR, a fiberboard box manufacturer who provides knocked down, unassembled boxes that are certified by its customer as meeting a UN standard and assembled by the customer is considered to be a packaging component manufacturer. A packaging component manufacturer need not maintain any record of testing done on the assembled UN 4G packaging even when it may have marked the outer packaging with a certification at its customer’s behest. Both the UN standard packaging facility and/or a third-party approval agency certifying design qualification tests and periodic retests must ensure the tasks you perform as a component manufacturer are done in accordance with the HMR, and they must produce and retain test reports as prescribed in
§ 178.601(1).

The test reports must be maintained at each location where the packaging is manufactured and each location where the design qualification tests are conducted, for as long as the packaging is produced and for at least two years thereafter. In addition, the test reports must be maintained at each location where the periodic retests are conducted until such tests are successfully performed again and a new test report produced. When requested, the test report must be made available to a user of the packaging or a representative of the Department of Transportation.

I hope this satisfies your request.

Sincerely,

Hattie L. Mitchell, Chief
Regulatory Review & Reinvention
Office of Hazardous Materials Standards

173.197

Regulation Sections