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Interpretation Response #01-0086

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

Interpretation Response Details

Response Publish Date: 06-01-2001
Company Name: HMT Associates, L.L.C.    Individual Name: Mr. E. A. Altemos
Location state: DC    Country: US

View the Interpretation Document

Response text:

JUN 1, 2001


Mr. E. A. Altemos                      Ref. No. 01-0086
HMT Associates, L.L.C.
1850 K Street, N.W. Washington, D.C. 20006-3500

Dear Mr. Altemos:

This responds to your March 20, 2001 letter concerning the packaging requirements for solid sodium chlorite, UN 1496, a Division 5.1 material under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions). You state that the sodium chlorite is located inside a rigid plastic cartridge which is packaged in a 4G packaging. The inner 4G packaging is further packed in a 1 G fibre drum for shipment as a single package. Specifically, you request confirmation that a 1 G fibre drum with a 4G inner packaging may be considered as a single package for purposes of application of cargo aircraft package quantity limitations for domestic and international air transport.

The answer is yes. A 1 G fibre drum that is an authorized single packaging for a hazardous material may contain inner receptacles which are compatible with the lading as long as the inner receptacles would not adversely impact the level of performance of the packaging. The packaging would remain marked as a single packaging. Therefore, for purposes of determining the package quantity limitation for air, a 1 G fiberboard drum with an inner 4G packaging, may be considered a single package.

I hope this answers your inquiry.



Edward T. Mazzullo
Director, Office of Hazardous Materials Standards


Regulation Sections

Section Subject
§ 173.312 Requirements for shipment of MEGCs