Interpretation Response #05-0111R ([Reactives Management Corporation] [Ms. Cherie Walton])

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

Interpretation Response Details

Response Publish Date: 05/05/2010

Company Name: Reactives Management Corporation

Individual Name: Ms. Cherie Walton

Location State: VA Country: US

View the Interpretation Document

Response text:

May 5, 2010

Ms. Cherie Walton

Reactives Management Corporation

1025 Executive Blvd., Suite 101

Chesapeake, VA 23320

Ref. No.: 05-0111R

Dear Ms. Walton:

This is a follow up to your April 28, 2005 letter requesting clarification regarding the general packaging requirements specified under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You asked if it is permissible for a specification combination package (a UN 4G fiberboard box with inner metal receptacles), which was tested for liquids, to be filled with a solid material as long as the gross mass marked on the packaging is not exceeded. This letter is a revision to our original response from June 17, 2005.

The HMR, at § 178.602, require each packaging to be closed in preparation for testing and tests to be carried out in the same manner as if prepared for transportation, including inner packagings in the case of combination packagings. Therefore, a combination packaging design originally tested with inner packagings containing liquids may not be used to package solid materials, as a single package or otherwise, without further testing.

I hope this information is helpful. Should you have any further questions, please contact this office.

Sincerely,

Hattie L. Mitchell, Chief

Regulatory Review and Reinvention

Office of Hazardous Materials Standards

178.602

Regulation Sections