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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 #06-0124 ([Dangerous Goods Advisory Council] [Mr. Frits Wybenga])

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

Interpretation Response Details

Response Publish Date:

Company Name: Dangerous Goods Advisory Council

Individual Name: Mr. Frits Wybenga

Location State: DC Country: US

View the Interpretation Document

Response text:

Oct 5, 2005


Mr. Frits Wybenga                 Reference No. 06-0124
Technical Director
Dangerous Goods Advisory Council
Suite 740
1100 H Street, NW
Washington, DC 20005

Dear Mr. Wybenga:

This is in response to your May 12, 2006 letter concerning the definition of “non-bulk packaging” as defined in § 171.8 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180). Specifically, you ask this office to reconsider the interpretation in our May 23, 2005 letter to Wyle Laboratories regarding the definition of a “non-bulk packaging.”

Non-bulk packaging means a packaging that has a maximum net mass of 400 kg (882 pounds) or less a maximum capacity of 450 L (119 gallons) or less as a receptacle for a solid. It remains our opinion that the packaging Mr. Thomas R. Hamilton described is not a non-bulk packaging because it has a maximum capacity greater than 450 L (119 gallons). Outer Packagings, which contain solids (e.g., fireworks, articles, or other receptacles containing fireworks), must be measured in terms of their capacity as well as their net mass. The packaging described by Wyle Laboratories in its original letter would meet the definition of a “Large Packaging” and, based on its volumetric capacity, would be a bulk packaging. To make the definitions easier to understand, under Docket HM-231, published September 1, 2006 (71 FR 52017) we have proposed to revise the current definitions for “Bulk packaging,” “Large packaging,” and “Non-bulk packaging.”

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Susan Gorsky
Regulations Officer
Office of Hazardous Materials Standards

171.8, 173.24

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
173.24 General requirements for packagings and packages