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Interpretation Response #00-0138 ([Corrugated Container Corporation] [Mr. John Byers])

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

Interpretation Response Details

Response Publish Date:

Company Name: Corrugated Container Corporation

Individual Name: Mr. John Byers

Location State: VA Country: US

View the Interpretation Document

Response text:

June 28, 2000

Mr. John Byers                Ref. No. 00-0138
Corrugated Container Corporation
P.O. Box 20369
Roanoke, VA 24018

Dear Mr. Byers:

This is in response to your letter dated May 5, 2000, and subsequent telephone conversation with Eric Nelson of my staff requesting clarification of marking requirements for UN standard packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if the date when periodic retesting is required for a combination packaging is two years from the date of manufacture or the date of the original design qualification test.

The answer is the date of the original design qualification test.  A combination or composite packaging may be marked as being "manufactured" on the date on which the packaging was assembled.  "Assembly" is the physical act of placing inner packagings or a liner into an outer packaging.  It is important to note here that the date of a design qualification test or periodic retest and the date of manufacture are two different things.  The date marked on the packaging does not necessarily reflect the date the packaging was tested.

For example, a combination packaging that is tested in January 1998 may be manufactured anytime within 24 months after that test, and dated the year it is manufactured, which would be 1998, 1999, or 2000; or the packaging may be dated the year it is assembled, which could be any year thereafter.  Aside from the date the packaging is assembled, the packaging design must be retested by the end of January, 2000.

I hope this satisfies your request.


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


Regulation Sections

Section Subject
178.601 General requirements