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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #06-0016 ([Transport Management Group] [Mr. Timothy Wagner])

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

Interpretation Response Details

Response Publish Date:

Company Name: Transport Management Group

Individual Name: Mr. Timothy Wagner

Location State: DC Country: US

View the Interpretation Document

Response text:

May 3, 2006

Mr. Timothy Wagner                      Reference No. 06-0016


Transport Management Group

15400 Pearl Road # 236

Strongsville, OH 44136

Dear Mr. Wagner:

This responds to your January 17, 2006 letter requesting clarification concerning the use of a UN 1A2 steel drum containing a plastic inner receptacle under the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions). Specifically, you request clarification regarding the use of an open-head drum certified for liquids as an outer packaging for a combination packaging containing a plastic inner bottle without retesting as a combination packaging.

A UN 1A2 steel drum that is an authorized single packaging may contain inner receptacles that are compatible with the lading as long as the inner receptacles would not adversely impact the level of performance of the packaging. This configuration would comply with the HMR and the ICAO Technical Instructions. The packaging would remain marked as a single packaging.

I hope this information is helpful. Please contact us if you require additional assistance.


John A. Gale

Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.24a Additional general requirements for non-bulk packagings and packages