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Interpretation Response #00-0152 ([Green Bay Packaging Inc.] [Mr. David Teames])

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

Interpretation Response Details

Response Publish Date:

Company Name: Green Bay Packaging Inc.

Individual Name: Mr. David Teames

Location State: TX Country: US

View the Interpretation Document

Response text:

January 9, 2001

Mr. David Teames                Ref. No. 00-0152
Design Manager
Green Bay Packaging Inc.
7901 S. Freeway
Fort Worth, TX 76134

Dear Mr. Teames:

This is in response to your letter requesting clarification of the requirements for certification of a UN standard packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-­180).  Specifically, you inquire whether a deliberate 1/8" increase in depth in the dimensions of an outer packaging would constitute a new design under §178.601(c)(4) and would, and therefore, require qualification testing.  You enclosed a letter from the packaging assembler who assumes responsibility as the manufacturer of the packaging.  In the letter, the manufacturer of the packaging states that this modification is not considered a different packaging under the HMR.

The manufacturer is incorrect.  Under the HMR, the manufacturer identified on the packaging has the responsibility to ensure that the packaging meets the UN standard to which it is certified.  As set forth in §178.601(c)(4), a change in structural design, size, material of construction, wall thickness or manner of construction is a different packaging.  The only variances allowed are those set forth in §178.601(c)(4)(i) through (vi) and §178.601(g). Therefore, any intentional increase in the dimensions of a packaging would be considered a different packaging and, therefore, require design qualification testing.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Stan


Regulation Sections

Section Subject
178.601 General requirements