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Interpretation Response #00-0263

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

Interpretation Response Details

Response Publish Date: 11-16-2000
Company Name: McCarthy, Sweeney & Harkaway, P.C.    Individual Name: Mr. Lawrence W. Bierlein
Location state: DC    Country: US

View the Interpretation Document

Response text:

November 16, 2000

Mr. Lawrence W. Bierlein                Ref. No. 00-0263
McCarthy, Sweeney & Harkaway, P.C.
Suite 600
2175 K Street, N.W.
Washington, D.C. 20037

Dear Mr. Bierlein:

This is in response to your September 22, 2000 letter regarding selective testing variations for packagings under the Hazardous Materials Regulations (HMR, 49 CFR Parts 171 to 180).  Your request concerned the applicability of the selective testing variations found in §178.601(g) to a packaging for a material that is toxic by inhalation.

As provided by §173.226(c), a material that is toxic by inhalation in Hazard Zone A may be packaged in a combination packaging consisting of an inner packaging system and an outer packaging.  The inner packaging system consists of an impact resistant inner receptacle packed within a leak-tight packaging.  This combination packaging in turn is packed within the outer packaging.  Both the inner packaging system and the outer packaging must conform to the performance test requirements of subpart M of part 178.  You ask if an inner packaging system which has been tested to packing group I performance level may utilize the variations provided in §178.601 (g).

If the inner packaging system is tested in accordance with the requirements in subpart M of Part 178 and marked in accordance with §178.503 as a UN standard packaging, then you may use the variations provided in §178.601 (g).  If the inner packaging system has not been marked as a UN standard packaging, there is no provision for variations of inner packagings.

I hope this satisfies your request.


Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards


Regulation Sections

Section Subject
§ 173.226 Materials poisonous by inhalation, Division 6.1, Packing Group I, Hazard Zone A