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Interpretation Response #11-0302 ([Navarro Research and Engineering, Inc.] [Mr. David Wilson])

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

Interpretation Response Details

Response Publish Date:

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