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Interpretation Response #05-0285

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

Interpretation Response Details

Response Publish Date: 01-24-2006
Company Name: Dangerous Goods    Individual Name: Mr. Larry Snellings
Location state: TX    Country: US

View the Interpretation Document

Response text:

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

178.513, 178.514

Regulation Sections

Section Subject
§ 178.513 Standards for boxes of natural wood