Interpretation Response #00-0272
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
November 7, 2000
Mr. Matt Hatfield Ref. No.00-0272
Hazardous Materials Analyst
Occupant Safety Systems
11202 East Germann Road
Queen Creek, AZ 85242-9361
Dear Mr. Hatfield:
This is in response to your September 20, 2000 letter requesting a clarification on whether a packaging used for Class 9 air bag inflators and modules, packaged under § 173-166(e)(3) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), would be considered a single or a combination packaging.
You describe the packaging as an inner fiberboard locator tray positioned in the bottom of an outer fiberboard box. The air bags are positioned securely in the locator tray and covered with a fiberboard divider which encloses the top and two sides. A second fiberboard locator tray is placed on the top of the first divider along with more air bags and a second divider. You state that this configuration was tested and certified as a 4G single packaging. However, you believe the configuration is a combination package.
Your packaging configuration is a combination packaging. A 4G packaging may be used as a single or a combination packaging, depending upon the packaging provision authorization. A combination packaging is one that consists of an outer non-bulk packaging (e.g., a fiberboard box) and a separate inner packaging that is a " containment vessel."t; See definitions in § 171.8. Section 173.166(e) authorizes the use of an outer 4G packaging meeting the Packing Group III performance level for the prescribed inner packagings, i.e. the air bag devices. The inner packagings (devices) must be secured within the 4G packaging to prevent movement during transportation.
I hope this satisfies your request.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 173.166||Safety devices|