Interpretation Response #02-0025 ([LPS Industries, Inc.] [Gary Flaherty])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: LPS Industries, Inc.
Individual Name: Gary Flaherty
Location State: NJ Country: US
View the Interpretation Document
Response text:
February 8, 2002
Mr. Gary Flaherty Reference No. 02-0025
LPS Industries, Inc.
10 Caesar Place
Moonachie, NJ 07074
Dear Mr. Flaherty:
This is in response to your letter requesting clarification of the requirements under the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) regarding § 173.27(c) and paragraph 5.0.2.12.2 in the International Air Transport Association's Dangerous Goods Regulations (IATA DGR). You ask whether a packaging must be retested when a supplementary packaging is used for a combination packaging for transportation by aircraft. You also ask how changes to § 173.27 impact IATA's requirement.
We have made no changes to § 173.27, however; IATA.amended DGR's 5-
paragraph 5.0.2.1 .2 to require a "leak-proof liner, plastic bag or other equally efficient means of containment" for a supplemental-packaging. As you discussed in a telephone conversation with a member of our staff, under the HMR, you are not required to retest the combination packaging unless the addition of any of these means of containment changes the structural design of the combination packaging or its capability to meet the prescribed tests and conform to the requirements of § 173.24 (see § 178.601).
I hope this information is helpful. Please contact this office if may be of further assistance.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
173.27
Regulation Sections
| Section | Subject |
|---|---|
| 173.27 | General requirements for transportation by aircraft |