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Interpretation Response #12-0098 ([Smithers Pira] [Mr. Steve Dely])

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

Interpretation Response Details

Response Publish Date:

Company Name: Smithers Pira

Individual Name: Mr. Steve Dely

Location State: MI Country: US

View the Interpretation Document

Response text:

July 12, 2012



Mr. Steve Dely
Senior Project Engineer
Smithers Pira
6539 Westland Way, Suite 24
Lansing, MI 48917
Ref. No. 12- 0098

Dear Mr. Dely:

This responds to your April 18, 2012 letter requesting clarification on the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). In your letter, you reference the definition of an inner packaging, package, and receptacle under 
§ 171.8. You note that the definition of "receptacle" states "including any means of closing." Specifically, you ask if the receptacle must include a means of closure, or, does it mean if a receptacle has a means of closure, then that would be considered part of the receptacle.

The definition of "receptacle" in § 171.8 indicates that the means of closure is part of the receptacle. In addition, closures are required on packagings, packages, and receptacles as part of the package specification, and function as part of the containment of the hazardous material. Closure instructions are required to be provided with the certified package in accordance with provisions in § 178.2. Closure instructions must include any procedures to be followed including instructions for closing inner packagings and receptacles.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.



Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

171.8, 178.2

Regulation Sections

Section Subject
171.8 Definitions and abbreviations