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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 #11-0165 ([Thermofisher] [Ms. Melissa Russell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Thermofisher

Individual Name: Ms. Melissa Russell

Location State: MI Country: US

View the Interpretation Document

Response text:

October 18, 2011




Ms. Melissa Russell


4481 Campus Drive

Kalamazoo, MI 49008

Reference No. 11-0165

Dear Ms. Russell:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the term "positive means of closure." Specifically, you ask what is the additional "positive means" of closure requirement to the tape, wire and shrink-wrap as specified in the HMR (e.g., §§ 173.4a(e)(2) and 173.27(d)) for a cap that has a tamper-evident seal ("non-backoff" cap). You state that the tamper-evident cap has a break-away ring such as the cap on a 20-ounce bottle of soda or on a gallon of milk. You also state that the non-backoff cap locks the closure to a container to avoid unwanted loosening.

In addition to tape, wire and shrink-wrap, the HMR does not specify other methods of a positive means of closure. However, it is the opinion of this Office that the tamper-evident cap you reference does not meet the HMR positive means of closure requirement. To ensure that the closures are held securely in place during transportation, you may wish to contact the packaging manufacturer for additional methods to those given as examples in the HMR.

I hope this information is helpful. Please contact this office should you have additional questions.


T. Glenn Foster

Chief, Regulatory Review and Reinvention

Standards and Rulemaking Division

173.27(d), 173.4a

Regulation Sections

Section Subject
173.27 General requirements for transportation by aircraft
173.4a Excepted quantities