Interpretation Response #04-0272 ([Fisher Scientific Chemical Division] [Ms. Jeanette DeGennaro])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Fisher Scientific Chemical Division
Individual Name: Ms. Jeanette DeGennaro
Location State: NJ Country: US
View the Interpretation Document
Response text:
May 3, 2005
Ms. Jeanette DeGennaro ; Reference No. 04-0272
Senior Regulatory Specialist
Fisher Scientific Chemical Division
1 Reagent Lane
Fair Lawn, NJ 07410-2802
Dear Ms. DeGenearo:
This is in response to your November 24, 2004 letter and subsequent telephone conversation with Arthur Pollack of my staff regarding manufacturing of non-bulk packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provided the following scenario:
A combination package design type passes all required tests under Part 178, Subpart M. Twenty-four months later the design is re-tested with changes to the closure method (e.g., the torque setting on the bottle cap is increased) and the design also passes all required tests. You ask if you may use identical components from the previously tested design type for the new design type.
The answer is yes. Provided the package components manufactured prior to the re-test date are identical to those tested and no changes are made to the materials of construction or the dimensions of the packaging, the older components may be used.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
178. Subpart M