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Interpretation Response #07-0174 ([Citronix, LP] [Mr. Chris A. DuBois])

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

Interpretation Response Details

Response Publish Date:

Company Name: Citronix, LP

Individual Name: Mr. Chris A. DuBois

Location State: TX Country: US

View the Interpretation Document

Response text:

March 17, 2008

Mr. Chris A. DuBois

Product Manager

Citronix, LP

3030 SE Loop 820

Forth Worth, TX 76140

Ref. No.: 07-0174

Dear Mr. DuBois:

This is in response to your August 31, 2007, email requesting clarification on closure requirements for packagings containing hazardous materials transported by aircraft in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

According to your letter, your company ships liquid hazardous material in combination packages with inner receptacles consisting of 4 ounce or 16 ounce bottles. The closures consist of an ultrasonically sealed foil and plastic material (induction seal) and a screw cap fitted over the seal. The combination package is tested and certified to conform to the UN packaging requirements of Part 178 and the additional requirements of § 173.27. Section 173.27(d) requires each screw-type closure on any packaging to be secured to prevent the closure from loosening due to vibration or substantial change in temperature. It is your understanding that since the bottle is physically sealed without the screw cap, the closure is the induction seal, not the screw cap and the requirements of § 173.27(d) would not apply.

Since the tested combination package has inner receptacles fitted with a screw cap, the screw cap must be secured in accordance with § 173.27(d). This applies regardless of whether the inner receptacle also employs an induction seal. If the screw-cap closure is secured in a manner that prevents it from loosening due to vibration or substantial change in temperature, the requirement of § 173.27(d) has been met.

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

Sincerely,

Edward T. Mazzullo

Director, Office of Hazardous

Materials Standards

173.27

Regulation Sections