Interpretation Response #02-0167 ([Corrugated Supplies Corporation] [Tony Senzel])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Corrugated Supplies Corporation
Individual Name: Tony Senzel
Location State: IL Country: US
View the Interpretation Document
Response text:
Aug 2, 2002
Mr. Tony Senzel Reference No. 02-0167
Quality Manager
Corrugated Supplies Corporation
5101 West 65th Street
Chicago, IL 60630
Dear Mr. Senzel:
This responds to your June 5, 2002 letter requesting clarification on basis weight tolerance for UN certified boxes under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask what is the basis weight tolerance allowed under the HMR.
In your letter, you give an example of a third party UN approved laboratory certifying a package with a paper combination of 42/23/42 (lbs/MSF). After an audit and additional testing, it is determined that the package has an actual basis weight combination of 40.8/25.1/42.0. You ask if this deviation in the basis weight is a basis for rejection and a violation under the HMR.
It is the opinion of this Office that the packaging with the different basis weight is a "different packaging" because it is not identical to the packaging tested. Accordingly, the different design must be tested as required in 49 CFR Part 178, Subpart M.
I hope this answers your inquiry.
Sincerely,
Delmer F. Billmigs
Chief, Standards Development
Office of Hazardous Materials Standards
178