USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #10-0200 ([Hazmat - CDMAT] [Mr. Harry Woods])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazmat - CDMAT

Individual Name: Mr. Harry Woods

Location State: CA Country: US

View the Interpretation Document

Response text:

December 3, 2010




Mr. Harry Woods

Fire Prevention Supervisor

Hazmat - CDMAT

1010 Second Avenue, Suite 300

San Diego, CA 92101-4970

Ref. No.: 10-0200

Dear Mr. Woods:

This responds to your September 17, 2010 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your email and subsequent telephone conversation with a member of my staff, you request clarification of the applicability of § 178.601(g)(2) to a combination package containing ethanol. Your questions are paraphrased and answered as follows:

Q1) Is § 178.601(g)(2) referenced in the Hazardous Materials Table (HMT; § 172.101) for non-bulk packagings of liquid hazardous materials?

A1) No. Section 178.601(g)(2) is not directly referenced in the HMT. Part 178, pertaining to specifications for packagings, is referenced in the non-bulk specification packagings for liquid hazardous materials in §§ 173.201 (Packing Group I), 173.202 (Packing Group II) and 173.203 (Packing Group III). Sections 173.201, 173.202, and 173.203 are referenced in Column 8B of the HMT, as applicable.

Q2) May a combination packaging for ethanol consisting of a 4G fiberboard box and inner plastic receptacle tested according to § 178.601(g)(2) be used for liquid hazardous materials?

A2) With respect to ethanol, the answer is yes. The listings for ethanol in the HMT indicate that non-bulk packaging must comply with either § 173.202 or § 173.203 based on the Packing Group assigned. Both sections authorize outer 4G fiberboard boxes with inner plastic receptacles. The non-bulk performance-oriented packaging standards for fiberboard boxes are provided in § 178.516 and the testing requirements are provided in Part 178, Subpart M. Section 178.601(g)(2) applies when packagings are different only in minor respects from a tested packaging. It allows for an outer packaging to be used with different inner packagings, provided that it has been successfully tested in accordance with § 178.603 with fragile inner packagings containing liquids at the Packing Group I drop height and the combined gross mass of the inner packagings does not exceed one-half the gross mass of the inner packagings used to perform the drop test.

It should be noted that combination packages consisting of 4G fiberboard boxes and inner plastic receptacles are not authorized for all liquid hazardous materials. To determine the authorized packaging for any hazardous material, you must first find the proper shipping name in the HMT and then refer to Column 8, which lists the section in Part 173 containing the authorized packaging for that particular hazardous material.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division


Regulation Sections

Section Subject
178.601 General requirements