Interpretation Response #08-0238 ([Emerson Process Management] [Mr. Scott A. Ferguson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Emerson Process Management
Individual Name: Mr. Scott A. Ferguson
Location State: TN Country: US
View the Interpretation Document
Response text:
November 19, 2008
Mr. Scott A. Ferguson
Emerson Process Management
835 Innovation drive
Knoxville, TN 37932
Ref. No.: 08-0238
Dear Mr. Ferguson:
This responds to your October 1, 2008 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the term "manufacturing joints" as used in §178.516(b)(3) of the HMR.
Section 178.516 specifies standards for a 4G fiberboard box. Paragraph (b)(3) requires manufacturing joints in the bodies of boxes, if part of the design, to be taped, lapped and glued, or lapped and stitched with metal staples. According to your letter, you manufacture a 4G box that includes a die cut top flap with side tuck flaps. You state that the 4G box has passed the performance tests in Subpart M of Part 178. You ask whether the flaps must be taped, lapped and glued, or lapped and stitched with metal staples in accordance with §178.516(b)(3).
The answer is no. Based on our review of the pictures and information provided in your letter, the box you manufacture satisfies the requirements in §178.516 for a 4G fiberboard box.
I hope this answers your inquiry.
Sincerely,
Susan Gorsky
Acting Chief, Standards Development
Office of Hazardous Materials Standards
178.516(b)(3)
Regulation Sections
| Section | Subject |
|---|---|
| 178.516 | Standards for fiberboard boxes |