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Interpretation Response #09-0263R ([TEN-E Packaging Services, Inc.] [Mr. Robert Eyck])

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

Interpretation Response Details

Response Publish Date:

Company Name: TEN-E Packaging Services, Inc.

Individual Name: Mr. Robert Eyck

Location State: MN Country: US

View the Interpretation Document

Response text:

May 5, 2010

 

 

 

 

Mr. Robert Eyck

TEN-E Packaging Services, Inc.

1666 County Road 74

Newport, MN 55055

Ref. No.: 09-0263R

Dear Mr. Eyck:



This responds to your October 13, 2009 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to non-bulk packaging used to transport hazardous materials. Specifically you ask whether separate tests are required for inner receptacles of combination packagings that are intended to contain both liquid and solids. This is a revision to our original response from December 10, 2009.

The HMR, at § 178.602, require each packaging 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. Should have any further questions, please contact this office.

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

178.602

Regulation Sections