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Interpretation Response #04-0068 ([Inland Paperboard and Packaging, Inc] [Mr. 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: Mr. John H. Rutherford

Location State: IN Country: US

View the Interpretation Document

Response text:

Feb 22, 2006


Mr. John H. Rutherford                 Reference No. 04-0068
Inland Paperboard and
   Packaging, Inc.
8501 Moller Road
Indianapolis, IN 46268

Dear Mr. Rutherford:

This responds to your letter requesting clarification of the non-bulk packaging testing requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether it is permissible for the inner packaging of a combination packaging design to leak when drop tested. In the scenario you describe, the leaking inner packaging contains a non-regulated material. The inner packagings containing regulated hazardous materials in the combination packaging design do not leak when subjected to the drop test protocol under 178.603. I apologize for the delay in responding and any inconvenience it may have caused.

The answer to your question is no. Under § 178.603(f) (4) of the HMR, there may be no leakage of the filling substance from the inner packaging(s) of a combination or composite packaging design, hazardous or otherwise, in order to successfully pass the drop test. In addition, the leaking substance, hazardous or otherwise, may have an adverse effect on inner or outer packaging integrity under conditions encountered while in transportation.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



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


Regulation Sections

Section Subject
178.601 General requirements