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Interpretation Response #00-0283 ([Timberline Packaging Incorporated] [Mr. Gary L. Cohen])

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

Interpretation Response Details

Response Publish Date:

Company Name: Timberline Packaging Incorporated

Individual Name: Mr. Gary L. Cohen

Location State: PA Country: US

View the Interpretation Document

Response text:

November 2, 2000

Mr. Gary L. Cohen                Ref. No: 00-0283
Timberline Packaging Incorporated
400 Technology Drive
Coal Center, PA 15423

Dear Mr. Cohen:

This is in response to your October 6, 2000 letter regarding the manufacture of packagings to UN Standards under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You state that Timberline Packaging manufactures UN packagings for their customer Shandon, Inc.  Shandon, Inc. provided the specifications for the packaging they want Timberline to manufacture including the specification markings to be printed on the packaging (i.e., UN4G /Y5.5/S/00[USA/+BE00210).  Shandon, Inc. has now asked that Timberline sell this carton directly to another company, Polysciences Corporation . You ask whether you may sell this carton to Polysciences Corporation.

The answer is yes.  The responsibility that Timberline Packaging has is to manufacture a packaging to the exact specifications provided to you.  The specification marking you apply identifies the third party laboratory that certified the design type and Shandon, Inc. as the manufacturer of the packaging.  Selling the packaging to another company does not  "transfer the certification" as you state in your letter.

I hope this information is helpful.


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


Regulation Sections

Section Subject
178.601 General requirements