USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

Interpretation Response #07-0009 ([gh Package & Product Testing and Consulting, Inc.] [Mr. H. Perry Hock])

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

Interpretation Response Details

Response Publish Date:

Company Name: gh Package & Product Testing and Consulting, Inc.

Individual Name: Mr. H. Perry Hock

Location State: DC Country: US

View the Interpretation Document

Response text:

Mar 20, 2007

Mr. H. Perry Hock                             
Reference No. 07-0009
Technical Director
gh Package & Product Testing
and Consulting, Inc.
4090 Thunderbird Lane
Fairfield, OH 45014-2234

Dear Mr. Hock:

This is in response to your January 16, 2007 letter regarding selective testing of packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if partition dividers may be added to a packaging tested in accordance with Variation 2 under § 178.601(g)(2).

The answer is yes, provided the dividers do not replace any integral cushioning material present in the original testing of the packaging design type. Variation 2 allows inner
packagings of any type in an outer packaging without retesting if the specific conditions of the variation are met. Therefore, as long as the conditions in § 178.601(g)(2) are met, the addition of dividers does not require further testing.

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


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


Regulation Sections

Section Subject
178.601 General requirements