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Interpretation Response #11-0200

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

Interpretation Response Details

Response Publish Date: 10-12-2011
Company Name: Wyle Laboratories    Individual Name: Mr. Brian Coppock
Location state: AL    Country: US

View the Interpretation Document

Response text:

October 12, 2011



Mr. Brian Coppock
Manager, Product Safety/Packaging Technology
Wyle Laboratories
7800 Highway 20 West
Huntsville, AL. 35806

Reference No. 11-0200

Dear Mr. Coppock:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to wooden large packagings. Specifically, you ask for us to clarify which evaluation criteria would be used in the stacking test with a large wooden packaging using static weights. You state that § 178.980(e) "Criterion for Passing the Test" addresses specific categories of large packagings, but that there is no reference for the criterion for a wooden large packaging undergoing a static weight test.

This appears to be an oversight and we are evaluating this issue to determine the need for a rulemaking. In the meantime, we recommend the criteria provided in § 178.980(e)(1). Also, in the HM-231, "Miscellanous Packaging Amendments," final rule that was published on September 30, 2010 (75 FR 60333), we stated that the design, construction and testing requirements are based on the UN Recommendations on the Transport of Dangerous Goods, Thirteenth Revised Edition (2003); Chapter 6.6, Requirements for the Construction and Testing of Large Packagings. Section provides the criteria for passing the stacking test for large packagings as, "No permanent deformation which renders the large packaging unsafe for transport and no loss of contents," to cover all of the large packaging construction types.

I hope this information is helpful. Please contact this office should you need additional assistance.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
§ 178.980 Stacking test