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Interpretation Response #05-0141 ([TEN-B Packaging Services, Inc.] [Mr. Robert J. Ten Eyck])

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

Interpretation Response Details

Response Publish Date:

Company Name: TEN-B Packaging Services, Inc.

Individual Name: Mr. Robert J. Ten Eyck

Location State: MN Country: US

View the Interpretation Document

Response text:

Jun 17, 2005


Mr. Robert J. Ten Eyck                         Reference No. 05-0141
Director, Technical Services
TEN-B Packaging Services, Inc.
1666 County Road 74
Newport, MN 55055

Dear Mr. Ten Byck:

This is in response to your June 3, 2005 letter regarding the selective testing variations under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if Variation 2 in § 178.601(g) applies to Division 2.1 materials (e.g., butane filled cigarette lighters).

You are correct in your understanding that Variation 2 applies to combination packagings designed and tested to contain liquids or solids and does not apply to flammable gases. In accordance with Special Provision N10 of § 172.102, lighters in their approved inner packagings must be packaged in one of the following outer packagings that have been design qualified tested at the Packing Group II performance level or higher: (1) 4C1 or 4C2 wooden boxes; (:2) 4D plywood boxes; (3) 4F reconstituted wood boxes; 4G fiberboard boxes; or (5) 4H1 or 4H2 plastic boxes. Under § 178.601(g), it is permissible to vary the number and type of approved lighter/inner packaging configurations that are packed in an outer UN standard packaging without further design qualification testing of the package, provided an equivalent level of performance is maintained.

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