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Interpretation Response #09-0094 ([Roche Molecular Systems, Inc.] [Ms. Julie Park])

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

Interpretation Response Details

Response Publish Date:

Company Name: Roche Molecular Systems, Inc.

Individual Name: Ms. Julie Park

Location State: NJ Country: US

View the Interpretation Document

Response text:

July 3, 2009



Ms. Julie Park

Sr. Safety & Environmental Professional

Roche Molecular Systems, Inc.

1080 U.S. Highway 202 South

Branchburg, NJ 08876

Ref. No. 09-0094

Dear Ms. Park:

This responds to your April 22, 2009, request for clarification of the requirements for transporting small quantities of hazardous materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification concerning whether packages that pass the tests specified in the International Safe Transit Association (ISTA) Procedure 2A conform to the testing requirements specified in

§ 173.4(a)(6).

According to your letter, your company manufactures and ships a variety of medical chemical testing kits that are tested in accordance with ISTA Procedure 2A. The ISTA Procedure 2A test protocols include vibration, free fall drop, and compressive load tests. The chemical kits are overpacked into double wall corrugated cardboard boxes for shipment.

Section 173.4 sets forth the conditions under which certain hazardous materials may be transported utilizing the exception for small quantities. Section 173.4(a)(6) requires each completed package, as demonstrated by prototype testing, to be capable of sustaining each of the drop tests in § 173.4(a)(6)(i) (A) through (E) and the compression test in § 173.4(a)(6)(ii). It is the opinion of this Office that the ISTA Procedure 2A testing protocols demonstrate that a package is capable of sustaining the drop tests and compression test if the drop height is adjusted to the 1.8m (5.9 feet) required by §173.4(a)(6)(i). Thus, packages that pass the ISTA 2A tests may be transported in accordance with the small quantity exception in § 173.4 provided all other listed conditions are met.

I hope this answers your inquiry.



Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.4 Small quantities for highway and rail