Interpretation Response #11-0047 ([HMT Associates, L.L.C.] [Mr. Edward A. Altemos])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: HMT Associates, L.L.C.
Individual Name: Mr. Edward A. Altemos
Location State: VA Country: US
View the Interpretation Document
Response text:
May 12, 2011
Mr. Edward A. Altemos
HMT Associates, L.L.C.
603 King St., Suite 300
Alexandria, VA 22314-3105
Reference No. 11-0047
Dear Mr. Altemos:
This is in response to your e-mail and our subsequent conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Special Provision (SP) 47, found in
§ 172.102(c)(1) of the HMR. You state that you are transporting "Solids containing flammable liquids, n.o.s.," (UN3175) which provides SP 47, and request clarification of the second sentence in SP 47 that reads as follows:
Except when the liquids are fully absorbed in solid material contained in sealed bags, each packaging must correspond with a design type that has passed a leakproofness test at the Packing Group II level.
You request confirmation of your opinion that this provision is not intended to apply to the inner packagings of combination packagings.
Your understanding is correct. A leakproofness test is not required for the inner packaging of a combination packaging. It should be noted, however, that for combination packagings to be shipped by air, the inner packagings must meet the pressure differential capability requirements specified in § 173.27(c).
I hope this information is helpful. Please contact this office should you have additional questions.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.102 SP 47, 173.27(c)
Regulation Sections
| Section | Subject |
|---|---|
| 173.27 | General requirements for transportation by aircraft |