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Interpretation Response #05-0238 ([Consultant] [Mr. Charles E. Tudor])

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

Interpretation Response Details

Response Publish Date:

Company Name: Consultant

Individual Name: Mr. Charles E. Tudor

Location State: CA Country: US

View the Interpretation Document

Response text:

Jan 31, 2006


Mr. Charles E. Tudor                          Reference No. 05-0238
3869 Mammoth Cave Court
Pleasanton, CA 04588

Dear Mr. Tudor:

This responds to your letter concerning the approval of equivalent packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180). Your questions are paraphrased and answered as follows:

Q1.      When the HMR authorize a 4D packaging, may a S0D large packaging be substituted without obtaining an approval?

Al.        The answer is no. There are no provisions in the HMR that authorize use of a large packaging in lieu of a non-bulk packaging.

Q2.      May a plywood box that exceeds the size and volume of a non-bulk packaging be tested and certified as a 4D without obtaining an approval?

A2.      The answer is no. A packaging that does not meet the definition in § 171.8 of a non-bulk packaging may not be tested and certified as a non-bulk packaging.

The HMR in § 178.801(i) authorize the use of a large packaging, as defined in § 171.8, if approved by the Associate Administrator. The large packaging must conform to the
construction standards, performance testing and packaging marking requirements specified in United Nation’s Recommendations on the Transport of Dangerous Goods. We may consider review of the FIMR definitions for bulk, non-bulk, and large packagings at some future date.

I trust this satisfies your request.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Material Safety

173.26, 178.500

Regulation Sections

Section Subject
173.26 Quantity limitations
178.500 Purpose, scope and definitions