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Interpretation Response #06-0270 ([Entegris, Inc.] [Mr. Kevin Bevis])

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

Interpretation Response Details

Response Publish Date:

Company Name: Entegris, Inc.

Individual Name: Mr. Kevin Bevis

Location State: MN Country: US

View the Interpretation Document

Response text:

Apr 11, 2007


Mr. Kevin Bevis                 Reference No. 06-0270
Containers Engineer
Entegris, Inc.
3500 Lyman Boulevard
Chaska, Minnesota 55318

Dear Mr. Bevis:

This responds to your letter requesting clarification of the non-bulk and IBC packaging design and testing criteria under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Ql.       We successfully tested three different non-bulk single packaging designs under the design qualification criteria specified in § 178.601(c) (1). Under selective testing Variation 5, in § 178.601(g) (5), if a replacement closure device or gasket successfully passes the required Variation 5 testing on one of the three designs presenting the most severe test conditions on the original design, is it permissible to use a replacement closure or gasket on the second and third design?

Al.        The answer is yes.

Q2.      Would the answer be the same if the second and third designs were qualified under the selective testing authorized in § 178.601(g) (3) (Variation 3)?

A2.      The answer is yes.

Q3.      Under the design qualification testing for IBCs in § 178.801(d), is it permissible to consider IBCs with identical bodies and with similar service equipment to be the same design type?

A3       The answer is yes, provided there are no changes made to other parts of the IBC (e.g., pallet base, cage support).

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



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

178.601 (g)(3), 178.801

Regulation Sections

Section Subject
178.601 General requirements
178.801 General requirements