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Interpretation Response #02-0124 ([Inland Paperboard and Packaging, Inc] [John H. Rutherford])

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

Interpretation Response Details

Response Publish Date:

Company Name: Inland Paperboard and Packaging, Inc

Individual Name: John H. Rutherford

Location State: IN Country: US

View the Interpretation Document

Response text:

Jul 11, 2002

Mr. John H. Rutherford                     Reference No. 02-0124
Manager, Testing Solutions Lab
Inland Paperboard and Packaging, Inc.
8501 Moller Road
Indianapolis, IN 46268

Dear Mr. Rutherford:

This is in response to your letter requesting clarification of selective testing Variation 2 under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Your customer has asked you to test and certify a combination package where the inner packagings are plastic bottles containing liquids as a Variation 2 packaging.  Your customer has interpreted § 178.601(g)(2)(i) to mean that glass is an example of a "fragile inner packaging."

Your questions are paraphrased and answered as follows:

Q1. Is it permissible to use plastic inner receptacles conditioned to -18°C (0°F) in lieu of glass for the drop test required in § 178.601(g)(2)(i)?

A1. The answer is yes.  Drop testing of combination packagings with plastic inner packagings intended to contain liquids must be carried out when the temperature of the test sample and its contents has been reduced to -18°C (0°F) (see § 178.603(c),

Q2. Can we certify our combination packagings for Variation 2 using plastic inner packagings?

A2. The answer is yes, provided the specific conditions of the variation are met.

Q3. Assuming we can test to Variation 2, should a statement be included in the certification report that the packaging qualifies under § 178.601(g)(2) for selective testing of combination packagings as long as no inner packagings more fragile than plastic at -18°C (0°F) are used?

A3. Such a statement is permissible, but not required.  Variation 2 allows inner packagings of any type in an outer packaging without retesting if the specific conditions of the variation are met.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


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


Regulation Sections

Section Subject
178.601 General requirements