Interpretation Response #12-0081 ([Hazardous Material Packaging, Inc.] [Mr. Bill Holbrook Allflex])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hazardous Material Packaging, Inc.
Individual Name: Mr. Bill Holbrook Allflex
Location State: PA Country: US
View the Interpretation Document
Response text:
September 13, 2012
Mr. Bill Holbrook
Allflex Hazardous Material Packaging, Inc.
100 Race St.
Ambler, PA 19002
Reference No.: 12-0081
Dear Mr. Holbrook:
This is in response to your March 20, 2012 letter and July 9, 2012 follow up letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to closure procedure requirements for inner packagings intended for use in the transportation hazardous materials. You describe several scenarios demonstrating your methods to determine a consistent and repeatable means of closure that is sufficient to ensure the packaging is closed in the same manner as it was tested, and ask if your methods meet the requirement in § 178.2(c)(1)(i)(B).
The closure instruction requirements noted in § 178.2(c)(1)(i)(B) require that closure instructions must provide for a consistent and repeatable means of closure that is sufficient to ensure the packaging is closed in the same manner as it was tested, unless specifically provided for in §§178.337"18 and 178.345"10.
Scenario #1
Cap and bottle are both marked with a straight line at the start of engagement of cap with bottle and after 1 full turn the additional distance is measured in inches to the point where the cap is fully tightened.
Scenario #2
Place a cap on a bottle and lightly turn the cap until it stops. Then mark the cap and bottle with a straight line. After marking the cap and bottle with a straight line an additional turn on the cap is made to make it tight and the distance in inches between the lines is measured. The distance between the lines (for example ¼ inch) would then be noted in the bottle closure instructions section of your test report and provided to purchasers.
Specific examples of acceptable processes that provide a consistent and repeatable means of closure necessary to ensure the packaging is closed in the same manner as it was tested are not provided in the HMR because these methods will vary depending on the type of packaging utilized. Any method that provides the filler of the inner packagings with instructions that allow them to prepare the inner packagings in the same manner as the inner package was prepared prior to successfully passing the design qualification testing required in subpart M of part 178 is acceptable. It is the opinion of this office that the terminology used to describe the closure methods for inner packages described in scenario #1 above is too vague to provide consistent and repeatable results that ensure the packaging is closed in the same manner as it was tested. The closure method described in scenario #2 in the opinion of this office appears to be a consistent and repeatable method.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
178.2(c)(1)(i)(B)