Interpretation Response #21-0021
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: XPO Logistics – Supply Chain
Individual Name: Erin Sineath
Location State: NC Country: US
View the Interpretation Document
Response text:
April 1, 2021
Erin Sineath
Global Manager of Dangerous Goods
XPO Logistics – Supply Chain
4043 Piedmont Parkway
High Point, NC 27265
Reference No. 21-0021
Dear Ms. Sineath:
This letter is in response to your March 4, 2021, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the definition of a "different packaging." Specifically, you indicate that closure instructions for a UN Specification 4G (fiberboard) packaging require the use of “3/16-inch Anti-Static Bubble wrap” for assembly. You ask whether it would be permissible to purchase a bubble wrap from another vender, as long as the same design specifications have been met.
The answer is yes. In accordance with § 178.601(c)(4), "a different packaging is one that differs (i.e., is not identical) from a previously produced packaging in structural design, size, material of construction, wall thickness or manner of construction." Therefore, having the bubble wrap manufactured by a different person does not automatically constitute a different packaging. However, please note that if the bubble wrap differs in design specification, it would constitute a different packaging.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
178.601(c)(4)
Regulation Sections
| Section | Subject |
|---|---|
| 178.601 | General requirements |