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Interpretation Response #11-0302

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

Interpretation Response Details

Response Publish Date: 04-02-2012
Company Name: Navarro Research and Engineering, Inc.    Individual Name: Mr. David Wilson
Location state: TN    Country: US

View the Interpretation Document

Response text:

April 2, 2012



Mr. David Wilson
Packaging and Transportation Project Manager
Navarro Research and Engineering, Inc.
669 Emory Valley Road
Oak Ridge, TN 37830

Reference No.: 11-0302

Dear Mr. Wilson:
This is in response to your November 17, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the reuse and reconditioning provisions of § 173.28. Specifically you ask if the reuse and reconditioning provisions of § 173.28 are applicable to Type B(U), Type B(M), and fissile material packagings.

The answer to your question is yes. Subpart I of part 173 describes the shippers general requirements for Class 7 (radioactive) materials. General design requirements are discussed in § 173.410. The introductory text to § 173.410 states that each package used for the shipment of Class 7 materials must be designed to the requirements of this section, as well as meet the requirements of subparts A and B of this part. The section you reference, § 173.28 is found in subpart B of part 173, and thus the reuse and reconditioning provisions found in § 173.28 apply to shipments of Type B(U), Type B(M), or fissile packagings.

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



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

173.410, 173.28

Regulation Sections

Section Subject
§ 173.410 General design requirements