Interpretation Response #09-0088 ([Roadrunner Rocketry, Inc.] [Mr. Bob Korman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Roadrunner Rocketry, Inc.
Individual Name: Mr. Bob Korman
Location State: TX Country: US
View the Interpretation Document
Response text:
June 25, 2010
Mr. Bob Korman
President
Roadrunner Rocketry, Inc.
116 Cascade Way
Coppell, TX 75019
Ref. No. 09-0088
Dear Mr. Korman:
This responds to your letter requesting clarification of the preparation requirements for testing non-bulk combination packaging and package designs under Subpart M of Part 178 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a combination packaging design (e.g., UN 4G), originally tested with inner packagings containing liquids, may be used to package solid materials without further testing. I apologize for the delay in responding to your letter and any inconvenience it may have caused.
The HMR, at § 178.602, require each packaging and package to be closed in preparation for testing and tests to be carried out in the same manner as if prepared for transportation, including inner packagings in the case of combination packagings. Therefore, a combination packaging design originally tested with inner packagings containing liquids may not be used to package solid materials, as a single package or otherwise, without further testing.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
178.602
Regulation Sections
| Section | Subject |
|---|---|
| 178.602 | Preparation of packagings and packages for testing |