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Interpretation Response #08-0310 ([SFB Plastic, Inc.] [Mr. John Fosse])

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

Interpretation Response Details

Response Publish Date:

Company Name: SFB Plastic, Inc.

Individual Name: Mr. John Fosse

Location State: KS Country: US

View the Interpretation Document

Response text:

February 4, 2009

Mr. John Fosse

Vice President-Sales

1819 W. Harry Street

Wichita, KS 67213

Ref. No. 08-0310

Dear Mr. Fosse:

This responds to your November 20, 2008 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you are required to have separate packaging test records and separate report identification numbers for combination packagings that are identical (i.e., the same inner packagings, the same outer packaging and the same packaging configuration) except for closure method (e.g., one is closed using 2-inch tape while another is closed using glue).

The answer is no. You are required to maintain a record of each design qualification test in accordance with § 178.601(l). The test record must include a description of the packaging design type, including methods of closure. You may maintain a single test record and test report identification number for identical packagings that differ only in method of closure, provided each method of closure is documented in the test report and the packaging successfully passes the required tests when closed in accordance with each closure method identified in the test report.

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


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.601 General requirements