Interpretation Response #01-0167 ([The Compliance Center Inc] [Ms. Dawn M. Anderson])

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

Interpretation Response Details

Response Publish Date: 10/31/2001

Company Name: The Compliance Center Inc

Individual Name: Ms. Dawn M. Anderson

Location State: NY Country: US

View the Interpretation Document

Response text:

October 31, 2001

Ms. Dawn M. Anderson                      Reference  No. 01-0167

The Compliance Center Inc

2150 Liberty Drive

Niagara Falls, NY 14304

Dear Ms. Anderson:

This responds to your June 22, 2001 letter requesting clarification of requirements for cushioning material used in packagings manufactured in accordance with Variation 2 in § 178.601 (g)(2) of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180).

Specifically, you asked if your understanding is correct that cushioning material used in Variation 2 packagings must be such that: 1) the thickness of cushioning material surrounding each inner packaging is at least as great as the thickness of the cushioning material in the originally tested packaging; 2) if the inner packagings contain liquids, the absorbent material. must be capable of absorbing the entire liquid contents of the inner packaging, and must be placed in a leakproof liner; 3) the cushioning material must be compatible with the contents of the inner packagings; and 4) any suitable cushioning material may be used, if it meets the requirements of items I through 3 above, and the gross weight of the completed packaging does not exceed the marked gross weight of the packaging certified under Variation 2.

Your understanding is correct.  In accordance with the requirements for packagings under Variation 2, as specified in § 178.601(g)(2), the thickness of cushioning material between inner packagings and between inner packagings and the outside of the packaging may not be reduced below the corresponding thickness in the originally tested packaging.  When a single inner packaging was used in the original test, the thickness of cushioning between inner. packagings may not be less than the thickness of cushioning between the outside of the packaging and the inner packaging in the original test.  When either fewer or smaller inner packagings are used, sufficient additional cushioning material must be utilized to take up void spaces.

I hope this satisfies your inquiry.  If we can be of farther assistance, please contact us.

Sincerely,

Delmer F. Billings

Chief, Standards Development

Office of  Hazardous Materials Standards

178.60

Regulation Sections