Interpretation Response #10-0214 ([DGM USA Atlanta] [Mr. Jim Shimko])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: DGM USA Atlanta
Individual Name: Mr. Jim Shimko
Location State: GA Country: US
View the Interpretation Document
Response text:
December 17, 2010
Mr. Jim Shimko
General Manager
DGM USA Atlanta
2000 Sullivan Road, Suite D
College Park, GA 30337
Reference No. 10-0214
Dear Mr. Shimko:
This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packagings. Specifically, you ask whether inner packagings of combination UN standard packagings designed to retain liquids must comply with the internal test pressure requirements prescribed in § 173.27(c)(2)(i) when they contain non-hazardous materials. You state the completed packages will also contain inner packagings of hazardous materials and are intended for transportation by aircraft.
While the inner packaging of a combination packaging that contains a non-hazardous material is not subject to the performance requirements for hazardous materials packagings under the HMR, including § 173.27(c)(2)(i), the completed packaging that contains inner packagings for hazardous and non-hazardous materials must meet all performance design tests for which it is certified (see § 178.3(a)). In addition, inner packagings of non-hazardous materials placed in a packaging with hazardous materials must not be capable of reacting dangerously with the packaging or its contents, or weaken the protective properties of the packaging. See §§ 173.21(e) and (g), 173.24(b) and (e), and 173.24a(a)(3).
I hope this satisfies your request.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemakings Division
173.27, 178.3
Regulation Sections
| Section | Subject |
|---|---|
| 173.27 | General requirements for transportation by aircraft |