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

Interpretation Response #11-0068 ([P&G] [Mr. Alvin J. Bernstein])

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

Interpretation Response Details

Response Publish Date:

Company Name: P&G

Individual Name: Mr. Alvin J. Bernstein

Location State: OH Country: US

View the Interpretation Document

Response text:

October 13, 2011



Mr. Alvin J. Bernstein


Mason Business Center (MBC)

8700 Mason Montgomery Road

Mason, OH 45040

Ref. No. 11-0068

Dear Mr. Bernstein:

This responds to your letter regarding package test protocol under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a separate drop and stack testing is required for combination packages containing liquids and solids where the inner packagings are of the same design and the liquid inner packagings have a higher mass than the solid. You state that it should be permissible to only test the package design for drop and stack capability that contains liquid substances and that a passing result should satisfy the testing requirement for the package containing solid substances. You also state that successful testing of the package design containing liquids should satisfy the small and excepted quantity testing requirements under §§ 173.4 and 173.4a of the HMR, respectively, and the international standards equivalent for excepted and limited quantity package design integrity, as well.

It is the opinion of this Office that you are correct in your determination of the test protocols required to assess the drop and stack testing capabilities of your particular packaging design in that successful testing of the design containing liquids would, in this particular scenario, also satisfy the requirement to test the design containing solids.

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


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

173.4, 173.4a

Regulation Sections

Section Subject
173.4 Small quantities for highway and rail
173.4a Excepted quantities