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Interpretation Response #00-0361 ([Bee Research Laboratory] [Mr. Jan Kochansky])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bee Research Laboratory

Individual Name: Mr. Jan Kochansky

Location State: MD Country: US

View the Interpretation Document

Response text:

February 5, 2001


Mr. Jan Kochansky                           Ref. No. 00-0361
Research Chemist
Bee Research Laboratory, Bldg. 476
10300 Baltimore Avenue
Beltsville, MD 20705-2350

Dear Mr. Kochansky:

This is in response to your December 18,2000 letter requesting clarification on the procedures for testing compatibility and rate of permeation in plastic packagings.  Specifically, you asked whether you may combine parts of the three test methods outlined in 49 CFR, Part 173, Appendix B.

Section 173.24(e) requires that plastic packagings used for liquid hazardous materials be capable of withstanding without failure the procedure specified in Appendix B to Part 173.  The procedure must be performed on all packagings used to transport liquid hazardous materials in Packing Group 1. However, for Packing Group II and III materials, capability to withstand this test can be demonstrated through previous handling and transportation experience or design specification.

Section 173.24(e)(3)(iii) permits alternative procedures to determine compatibility and permeation rate if they yield a level of safety equal to or greater than provided by paragraph (e)(3)(ii) and are approved by the Associate Administrator for Hazardous Materials Safety.  The procedures for submitting an application for approval are prescribed in 49 CFR 107.705.

I hope this satisfies your request.  Please contact us if we can be of further assistance.



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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table