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Interpretation Response #00-0216 ([Greif Bros. Corporation] [Mr. Gerald A. Gordon, Sc.D.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Greif Bros. Corporation

Individual Name: Mr. Gerald A. Gordon, Sc.D.

Location State: IL Country: US

View the Interpretation Document

Response text:

February 12, 2001


Mr. Gerald A. Gordon, Sc.D.                    Re No: 00-0216
Regulatory Compliance Specialist
Greif Bros. Corporation
245 Eisenhower Lane South
Lombard, Illinois 60148

Dear Mr. Gordon:

This is in response to your August 2, 2000, letter requesting clarification regarding what constitutes a “different packaging” under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask whether building a barrier into the sidewall of an otherwise identical fiber drum requires a new design qualification test.  You provided information to support your belief that such a change should not require testing as a “different packaging.”

It is your position that as long as critical mechanical and structural properties of the combined sidewall remain essentially the same, minor variations in sidewall composition (e.g., the presence of very thin layers of polyethylene or aluminum foil) should not cause the drum to be considered a “different packaging.”

We disagree.  You are changing both the design and manner of construction of the drum sandwiching layers of polyethylene or aluminum foil between the layers of fiberboard.  The drum is a “different packaging” as defined in § 178.601 and, therefore, design qualification testing is required.  If, however, a polyethylene or aluminum foil barrier is applied to the inside surface of a packaging, it is considered a surface treatment and is not considered a different packaging.

I hope this information is helpful.



Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards



Regulation Sections

Section Subject
178.601 General requirements