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
Section | Subject |
---|---|
173.27 | General requirements for transportation by aircraft |