Interpretation Response #09-0176 ([Chemtran Services USA, Inc] [Mr. Randy Hill])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Chemtran Services USA, Inc
Individual Name: Mr. Randy Hill
Location State: TX Country: US
View the Interpretation Document
Response text:
October 1, 2009
Mr. Randy Hill
Chemtran Services USA, Inc.
P.O. Box 62456
Houston, TX 77205-2456
Ref. No.: 09-0176
Dear Mr. Hill:
This responds to your July 23, 2009 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the testing of specification packagings. According to your letter, you successfully completed testing a UN 4GV combination package using a 1 gallon fragile glass jug as an inner packaging and vermiculite cushioning and absorbent material. You ask if you can replace the vermiculite absorbent material with polystyrene absorbent sheet pads and replace the vermiculite used to suspend the inner packaging inside the fiberboard outer packaging with a fiberboard sleeve without retesting the completed package.
The answer is no. The substitution of a different absorbent material and a different means of suspending the inner packaging inside of the outer packaging constitutes a new packaging design. Each new packaging design is subject to design qualification testing under Part 178, Subpart M.
I trust this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
178 Subpart M