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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0320 ([Defense Logistics Agency] [Ms. Linda McCarthy])

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

Interpretation Response Details

Response Publish Date:

Company Name: Defense Logistics Agency

Individual Name: Ms. Linda McCarthy

Location State: PA Country: US

View the Interpretation Document

Response text:

July 16, 2001

Ms. Linda McCarthy                Ref. No. 00-320
Defense Logistics Agency
2001 Mission Drive
New Cumberland, PA 17070-5000

Dear Ms. McCarthy:

This is in response to your letter and subsequent telephone conversation with a member of my staff requesting clarification of Variation 2 in 49 CFR 178.601(g). Specifically, you ask whether retesting is required for a combination packaging with one inner fiberboard box weighing 5 pounds if the packaging was tested with four 1 quart inner glass bottles weighing 2.5 pounds each.  You also ask whether there is a limit on the size of the inner fiberboard box.

Under § 178.601(g)(2), for combination packagings, Variation 2 allows inner packagings of any type in an outer packaging without retesting if the specific conditions of the variation are met.  There is no restriction on the size of the inner fiberboard box, however, it may not exceed half of the gross mass (the weight of the inner packagings plus the weight of the contents) of the inner packagings used for the drop test.  For air transport, packagings must also comply with § 173.27(c)(1) and (c)(2).  If all of the provisions in § 178.601(g)(2)(i)through (vii) are met, the combination packaging with one inner fiberboard box is not required to be retested.

I hope this information is helpful.  Please contact us if you need further assistance.


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


Regulation Sections

Section Subject
178.601 General requirements