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Interpretation Response #05-0095 ([Ropak Packaging, West Division] [Mr. Terry Iker])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ropak Packaging, West Division

Individual Name: Mr. Terry Iker

Location State: CA Country: US

View the Interpretation Document

Response text:

Nov 25, 2005


Mr. Terry Iker                       Reference No. 05-0095
Manager, Technical Services
Ropak Packaging, West Division
14585 Industry Circle
La Mirada, CA 90638

Dear Mr. Iker:

This is in response to your letter asking for clarification of periodic packaging testing under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if non-bulk packagings selected at random by the manufacturer for periodic retesting must be less than one year old.

The periodic retest requirements prescribed in § 178.601(c)(2), (e), and (f) do not specify the age of the non-bulk packagings to be tested. They are designed to serve as a quality control measure to ensure that all non-bulk, hazardous materials packagings manufactured since the last successful design qualification test or periodic retest, as applicable, are capable of meeting the appropriate UN performance standards. This can only be successfully demonstrated if the packagings se for testing are those manufactured since the last successful performance test for that design by that manufacturer. Therefore, after the design qualification tests required under § 178.601(c)(1) are successfully completed for each new or different packaging at the start of production, subsequent productions of the approved packaging design must be periodically retested as prescribed in § 178.601(c)(2), (e), and (f). As stated in § 178.60 1(e), a single or composite packaging must be periodically retested once every 12 months, and a combination packaging must be periodically retested once every 24 months. We believe this testing frequency and method e sufficient to ensure that all UN packagings are capable of passing the prescribed tests. Please note that a test report must be completed for each packaging design qualification test and each periodic retest as prescribed in § 178.601(1).

I hope this information is helpful.



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

178.601(c) (e) & (f)

Regulation Sections

Section Subject
178.601 General requirements