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Interpretation Response #00-0095 ([Professional Services Industries] [Mr. Paul B. Medwig and Mr. Scott Bischoff])

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

Interpretation Response Details

Response Publish Date:

Company Name: Professional Services Industries

Individual Name: Mr. Paul B. Medwig and Mr. Scott Bischoff

Location State: PA Country: US

View the Interpretation Document

Response text:

June 13, 2000


Mr. Paul B. Medwig and                Ref No. 00-0095
Mr. Scott Bischoff
Professional Services Industries
850 Poplar Street
Pittsburgh, PA 15220

Dear Messrs.  Medwig and Bischoff::

This is in response to your letter dated March 23, 2000, and subsequent telephone conversation with Eric Nelson of my staff regarding non-bulk package testing under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether an oxygen generator may be replaced by a "mock-up" oxygen generator for package testing when there would be no way of determining whether the oxygen generator fired during the test.

Section 178.602(a) requires each package be closed in preparation for testing and tests be carried out in the same manner as if the package was prepared for transportation.  A hazardous material  may be replaced by a non-hazardous material for package testing provided its physical properties, correspond as closely as possible to the hazardous material to be transported (See §178.602(p)). Special Provision 60 requires that each oxygen generator that is shipped with its means of initiation attached incorporate at least two positive means of preventing unintentional actuation and be classed and approved by the Associate Administrator for Hazardous Materials Safety.

In the case of oxygen generators, the requirements of §178.602 apply to the structural integrity of the packaging, not whether the generator fires.  The terms of an approval will authorize the means of preventing unintentional actuation.  Additional packaging performance requirements may be specified in an approval, especially if transportation by aircraft is authorized.

If this office can be of any further assistance, please contact us.

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table