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Interpretation Response #05-0025 ([C.L. Smith Company] [Mr. Lonnie Jaycox])

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

Interpretation Response Details

Response Publish Date:

Company Name: C.L. Smith Company

Individual Name: Mr. Lonnie Jaycox

Location State: MO Country: US

View the Interpretation Document

Response text:

Jul 27, 2005


Mr. Lonnie Jaycox                      Reference No. 05-0025
C.L. Smith Company
1311 South 39 Street
St. Louis, MO 63110-2535

Dear Mr. Jaycox:

This is in response to your January 26, 2005 letter regarding testing requirements for specification packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the addition of a liner bag and absorbent material in the void space of a previously tested combination packaging would require design qualification testing as “a different packaging.”

The answer is no, provided the addition of the liner and absorbent material do not effect the structural integrity of the combination packaging. “A different packaging” is defined in § 178.60 1(c)(4) as a packaging that differs from a previously produced packaging in structural design, size, material of construction, wall thickness or manner of construction. Therefore, further design qualification testing is not required if the alterations to the packaging do not constitute “a different packaging.” In addition, the completed and filled packaging, after the liner and absorbent material are added, may not exceed the gross weight of the originally tested packaging.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



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


Regulation Sections

Section Subject
178.601 General requirements