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Interpretation Response #10-0016 ([Entegris, Inc.] [Mr. Kevin Bevis])

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

Interpretation Response Details

Response Publish Date:

Company Name: Entegris, Inc.

Individual Name: Mr. Kevin Bevis

Location State: MN Country: US

View the Interpretation Document

Response text:

March 23, 2010




Mr. Kevin Bevis

Containers Engineer

Entegris, Inc.

101 Peavey Road

Chaska, MN 55318

Ref. No. 10-0016

Dear Mr. Bevis:

This responds to your January 19, 2010 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to design qualification packaging tests. Specifically, you ask if you may use the same three test samples to perform all of the required tests in §§ 178.601, 178.603, and 178.603-178.607.

According to your letter, you want to test a PFA inner, fiberglass+epoxy winding outer composite container (6HH1) using the same three samples for all test types, due to the robustness of the container and the cost of the parts. You ask if it is acceptable to use the same three samples to perform these tests on this packaging.

In accordance with § 178.601(k), several tests may be performed on a single sample with the approval of the Associate Administrator for Hazardous Materials Safety and provided the validity of the test results is not affected. You may apply for approval to perform several tests on a single sample under the procedures specified in 49 CFR § 107.705.

I hope this answers your inquiry. If you need additional assistance, contact this Office at



Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.601 General requirements