Interpretation Response #10-0246 ([W.E. Train Consulting] [Mr. W. Eugene Sanders])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: W.E. Train Consulting
Individual Name: Mr. W. Eugene Sanders
Location State: FL Country: US
View the Interpretation Document
Response text:
December 17, 2010
Mr. W. Eugene Sanders
Manager
W.E. Train Consulting
8710 W. Hillsborough Ave #112
Tampa, FL 33615
Ref. No.: 10-0246
Dear Mr. Sanders:
This responds to your November 2, 2010 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that in a previous letter of interpretation issued by PHMSA (06-0016), we permitted the use of an authorized single packaging, which was tested and marked for liquid hazardous materials, to contain inner receptacles that were compatible with the lading provided the inner receptacles would not adversely impact the level of performance of the packaging. Specifically, you ask whether this interpretation of the HMR continues to be in compliance.
The answer is yes. An authorized single packaging which is tested and marked for liquid hazardous materials may contain inner receptacles that are compatible with the lading provided the inner receptacles do not adversely impact the level of performance of the packaging. This configuration continues to comply with the HMR. Furthermore, the packaging would remain marked as a single packaging and be to subject to all requirements of the subchapter as a single packaging.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.24a