Interpretation Response #05-0285
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Jan 24, 2006
Mr. Larry Snellings Reference No. 05-0285
Vice-President, Dangerous Goods
P.O. Box 60543 AMF
Houston, TX 77205-0543
Dear Mr. Snellings:
This is in response to your October 27, 2005 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) to non-bulk performance-oriented packaging standards. Specifically, you ask for a definition of “other suitable means” used in the construction of natural wood and plywood boxes, respectively.
The standards for boxes containing natural wood or plywood are found in § 178.5 13 and 178.5 14, respectively. The HMR do not specifically define “other suitable means.” However, provided the strength of the material used is appropriate to the capacity and intended use of the box, the tops and bottoms of natural wood boxes may be made of materials similar to water-resistant reconstituted wood. Similarly, provided the strength of the materials used is appropriate to the capacity and intended use of the packaging, other materials may be used together with plywood in the construction of plywood boxes.
I trust this satisfies your inquiry.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials standards
|Standards for boxes of natural wood