Interpretation Response #02-0224 ([Boeing - Long Beach Division] [Scott W. Chapman])

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

Interpretation Response Details

Response Publish Date: 10/28/2002

Company Name: Boeing - Long Beach Division

Individual Name: Scott W. Chapman

Location State: CA Country: US

View the Interpretation Document

Response text:

Oct 28, 2002

Mr. Scott W. Chapman                   Reference No. 02-0224
Boeing - Long Beach Division
19270 Western Avenue
Torrance, CA 90501

Dear Mr. Chapman:

This is in response to your August 26, 2002 letter concerning package testing requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you requested clarification concerning the relative humidity requirements for testing paper and fiberboard packagings in § 178.602. You state that while the HMR requires margin of error of "2% in determining relative humidity, the machine you use has a margin of error of "5%.

Section 178.602 (d) requires the packaging to be maintained at least 24 hours prior to testing in an environment with 50% relative humidity, plus or minus 2%.  In addition, the requirements allow for up to a "5% deviation (45% or 55% relative humidity) for short term fluctuations in this minimum 24-hour period.  The average relative humidity would be calculated for at least 24 hours before the test, and would allow for "5% deviation spikes, but the average relative humidity must remain between 48% and 52%.

You equipment will need to be accurate enough to ensure that the pre-test environment falls within these specifications.  Your equipment and subsequent data display may be of any number of technologies or styles, but it is the responsibility of the equipment owner to be able to read and verify that the packaging was in an environment that meets these criteria for at least 24 hours prior to testing.  If you feel this criteria is too restrictive, then you may petition RSPA for a change to the regulations under the process outlined in § 106.31 of the 49 CFR.

I hope this satisfies your request.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

178.602

Regulation Sections