Interpretation Response #11-0195 ([Gh Package/Product Testing and Consulting, Inc] [Mr. Perry Hock])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Gh Package/Product Testing and Consulting, Inc
Individual Name: Mr. Perry Hock
Location State: OH Country: US
View the Interpretation Document
Response text:
November 16, 2011
Mr. Perry Hock
Gh Package/Product Testing and Consulting, Inc.
4900 Thunderbird Lane
Fairfield, OH
Ref. No.: 11-0195
Dear Mr. Hock:
This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171"180) applicable to the use of third party markings on packaging not authorized for use under the HMR. Specifically, you ask if a third party laboratory should assign its approval number to packagings (such as a large packaging, Intermediate Bulk Container, or non-bulk Packaging) that pass all required tests, but are still required to obtain approval from a DOT competent authority to ship the package.
The answer to your question is no. While the third party laboratory may provide a test report to the shipper, the shipper is still required to apply for a competent authority approval (CAA) for the packaging before the certification number can be assigned to the packaging.
I hope 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
178.3, 178.516
Regulation Sections
| Section | Subject |
|---|---|
| 178.516 | Standards for fiberboard boxes |