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Interpretation Response #06-0080 ([DG Supplies, Inc.] [Mr. Michael Bowen ])

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

Interpretation Response Details

Response Publish Date:

Company Name: DG Supplies, Inc.

Individual Name: Mr. Michael Bowen 

Location State: NJ Country: US

View the Interpretation Document

Response text:

Jun 6, 2006


Mr. Michael Bowen                 Reference No. 06-0080

Vice President

DG Supplies, Inc.

239 Prospect Plains Road

Monroe Township, NJ 08831

Dear Mr. Bowen:

This is in response to your March 22, 2006 letter requesting clarification of the general packaging requirements specified in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your company designs and tests fiberboard packagings intended to contain liquids and solids for air, ground and ocean shipments. You describe a particular combination packaging design for liquids, which utilizes molded-pulp inserts to secure glass bottles ranging from 0.5 - 4.0 liters within an outer fiberboard box (with no absorbent). You ask us to assume the completed package satisfies all necessary testing specified in Part 178. You also state the molded-pulp inserts could break down in composition if one of the bottles was to leak its contents. Specifically, you ask if the packaging you described satisfies the general securing and cushioning requirement in

§ 173.24a(a)(3) for non-bulk packagings and packages.

Unless otherwise excepted by the HMR, non-bulk packagings and packages intended

to contain hazardous materials must satisfy the general packaging requirements in

§ 173.24a. Under section § 173.24a(a)(3), cushioning material for non-bulk packagings or packages must not have its protective properties significantly weakened in the event of leakage. The packaging you describe does not satisfy the requirement because a breakdown in composition of the molded- pulp inserts could significantly weaken the protective properties of the cushioning material.

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



John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

173.24 (a)(3), 178.602

Regulation Sections

Section Subject
173.24 General requirements for packagings and packages
178.602 Preparation of packagings and packages for testing