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Interpretation Response #05-0037 ([Brand-Nu Laboratories, Inc.] [Mr. Paul Lombardo])

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

Interpretation Response Details

Response Publish Date:

Company Name: Brand-Nu Laboratories, Inc.

Individual Name: Mr. Paul Lombardo

Location State: CT Country: US

View the Interpretation Document

Response text:

Apr 26, 2005


Mr. Paul Lombardo                      Reference No. 05-0037
VP, Manufacturing
Brand-Nu Laboratories, Inc.
377 Research Parkway
Meriden, Connecticut 06450

Dear Mr. Lombardo:

This responds to your letter dated February 1, 2005, regarding the testing of specification packagings under the Hazardous Materials Regulations (HMR; CFR Parts 171-180). Specifically, you ask whether the one-liter amber glass bottle depicted in a drawing submitted with your letter meets the selective testing criteria in § 178.601(g) (1) and, therefore, would not require further testing of the package.

Provided the new bottle meets all of the pertinent criteria in § 178.601(g) (1) (e.g., similar design and shape, equivalent or smaller size, equivalent level of performance, same or smaller opening, and similarly designed closure), the originally tested design would not be required to be retested. This Office is not capable of making that determination.

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