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Interpretation Response #06-0019 ([3M Company] [Mr. Richard L. Sheehan])

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

Interpretation Response Details

Response Publish Date:

Company Name: 3M Company

Individual Name: Mr. Richard L. Sheehan

Location State: DC Country: US

View the Interpretation Document

Response text:

Mar 21, 2006

Mr. Richard L. Sheehan                                  
Reference No. 06-0019
Sr. Package Engineering Specialist
3M Company
Industrial Adhesives and Tapes Division
3M Center 230-1S-10
St. Paul, MN 55144

Dear Mr. Sheehan:

This responds to your letter concerning the reuse of fiberboard boxes under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask what performance standards apply to a reused packaging, and if an outer package may be reclosed by taping over old tape with new tape.

Taping over old tape with new tape would be acceptable if there is no damage to the packaging, it is reclosed in accordance with the closure instruction provided by the packaging manufacturer, and the surface treatment created by the old tape does not adversely affect the closure.

There are no separate performance standards for a reused packaging. Section 173.28(a) requires packagings and receptacles used more than once to be in such condition, including closure devices and cushioning materials, that they conform in all respects to the prescribed requirements in the HMR. Before reuse, each packaging must be inspected and may not be reused unless it is free from incompatible residue, rupture, or other damage that reduces its structural integrity.

I trust this satisfies your request.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings