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Interpretation Response #02-0026 ([TEN-E Packaging Services, Inc] [Robert J. Ten Eyck])

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

Interpretation Response Details

Response Publish Date:

Company Name: TEN-E Packaging Services, Inc

Individual Name: Robert J. Ten Eyck

Location State: MN Country: US

View the Interpretation Document

Response text:

March 15, 2002

Mr. Robert J. Ten Eyck                 Reference No.02-0026
Technical Services
TEN-E Packaging Services, Inc.
1666 Country Road 74
Newport, MN 55055

Dear Mr. Ten Eyck:

This responds to your letter dated December 20, 2001, regarding different packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you inquire whether the addition of a leak-proof liner to a previously tested fiberboard box design would require design qualification testing as a different design type under
§ 178.601(c)(4).

Provided the liner does not compromise the integrity of the original tested design type (e.g., packaging assembly, closure method), the addition of a liner or similar form of containment would not be considered a different packaging and, therefore, would not require design qualification testing as a new design type.

I trust this satisfies your inquiry.  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
178.601 General requirements