Interpretation Response #03-0066 ([Patrick J. Kelly Drums, Inc.] [Mr. Harold Aranow])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Patrick J. Kelly Drums, Inc.
Individual Name: Mr. Harold Aranow
Location State: PA Country: US
View the Interpretation Document
Response text:
Jun 13, 2003
Mr. Harold Aranow Ref. No.: 03-0066
Patrick J. Kelly Drums, Inc.
6226 Pidcock Creek Road
New Hope, Pennsylvania 18938
Dear Mr. Aranow:
This responds to your letter regarding the requirements for container closure notification information as prescribed in §178.2 under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked that the written notification requirement be amended to include a provision that would allow notification in electronic format on a CD Rom.
In accordance with the notification provision in § 178.2(c), the manufacturer and each subsequent distributor of a UN packaging must provide written notification instructions of all regulatory requirements not met at the time of transfer, such as instructions on how to properly assemble and close a packaging (e.g., UN 4G fiberboard box). Therefore, written (i.e., hard copy) notification must be provided to be in compliance with the provisions of § 178.2(c). An electronic format, such as a CD Rom, may be used as a supplement to the written notification.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards