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Interpretation Response #11-0048

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

Interpretation Response Details

Response Publish Date: 06-30-2011
Company Name: Container-Quinn Testing Laboratories, Inc.    Individual Name: Mr. Stephen C. Powell
Location state: IL    Country: US

View the Interpretation Document

Response text:

June 29, 2011



Mr. Stephen C. Powell
Lab Director
Container-Quinn Testing Laboratories, Inc.
170 Shepard Avenue
Wheeling, IL 60090

Ref. No. 11-0048

Dear Mr. Powell:

This responds to your February 22, 2011 request for clarification of package variation testing requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You describe a combination packaging where a 4G box is the outer packaging and the inner packaging is a sealed bag containing vermiculite and 1 or more glass receptacles evenly spaced within the vermiculite for the testing. You add weight to the bag to satisfy the gross mass requirements for drop testing in accordance with § 178.601(g)(2)(ii). Specifically, you ask if the package described in your letter is properly prepared and tested in accordance with the requirements for selective testing under variation 2 in § 178.601(g)(2).

The answer is no. The selective testing requirements in § 178.601(g)(2) (Variation 2) permit articles or inner packagings of any type, for solids or liquids, to be assembled and transported without testing in an outer packaging provided certain conditions are met. One condition in § 178.603(g)(2)(i) requires the outer packaging to successfully pass the drop test in § 178.603 with fragile inner packagings containing liquids at the Packing Group I drop height. In the scenario described in your letter, the glass receptacles are the "fragile inner packagings" and the bag is a secondary means of containment required in accordance with § 178.601(g)(2)(vi). The combined gross mass of inner packagings may not exceed ½ of the gross mass of the inner packagings used for the drop test. Thus, in the scenario described in your letter, any mass added to the inner packagings must be placed inside the glass receptacles for the drop test.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.


Ben Supko
Chief, Standards Development
Standards and Rulemaking Division


Regulation Sections

Section Subject
§ 178.603 Drop test