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Interpretation Response #04-0035 ([Estes-Cox Corporation] [Ms. Mary Roberts])

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

Interpretation Response Details

Response Publish Date:

Company Name: Estes-Cox Corporation

Individual Name: Ms. Mary Roberts

Location State: CO Country: US

View the Interpretation Document

Response text:

Apr 5, 2004


Ms. Mary Roberts                Reference No. 04-0035
Technical Services
Estes-Cox Corporation
P. 0. Box 227
Penrose, CO 81240-0227

Dear Miss Roberts:

This responds to your letter inquiring whether a very small fiberboard box can be tested and certified as a UN standard packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Estes-Cox Corporation manufactures Model rocket motors (NA 0323) and Igniters (UN 0454) which are shipped in performance oriented packagings to wholesalers and distribution centers where they are repackaged for shipment in smaller quantities to retailers and individuals throughout the United States.  Your company wants to eliminate the need for repackaging these items, and would like to test and certify a 3" x 1-3/4" x 7/8" fiberboard box to the UN 4G standard.  You enclosed a fiberboard box with two empty model rocket motor casings to illustrate the size of the proposed box.  Each UN 4G fiberboard box would be properly marked and labeled.  Several UN 4G fiberboard boxes would be placed inside an overpack for transportation.

The information provided to you by Ms. G. Corbin of this office that the fiberboard box specifications in
§ 178.516 do not specify a minimum size, but prescribe a maximum net mass for fiberboard boxes, was correct.  Section 178.516 does not prescribe a minimum size for fiberboard boxes.  Additionally, the UN Recommendations on the Transport of Dangerous Goods, Volume II, in state: “Labels shall be in the form of a square set at an angle of 450 (diamond-shaped) with minimum dimensions of 100 mm by 100 mm, except in the case of packages of such dimensions that hey can only bear smaller labels.” Section l72.401(c) of the HMR permits use of those modified labels on small packages of hazardous materials.

In addition, when an overpack is used, it must be marked with the proper shipping name and identification number, and labeled for each hazardous material it contains unless the markings and labels representative of each hazardous material in the overpack are visible.  The overpack must also be marked with a statement indicating that inside (inner) packages comply with prescribed specifications when specification packagings are required.

I trust this satisfied your inquiry.



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

178.516, 178.601

Regulation Sections

Section Subject
178.516 Standards for fiberboard boxes
178.601 General requirements