Interpretation Response #12-0229 ([Currie Associates, Inc.] [Ms. L'Gena Prevatt])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Currie Associates, Inc.
Individual Name: Ms. L'Gena Prevatt
Location State: NY Country: US
View the Interpretation Document
Response text:
December 3, 2012
Ms. L'Gena Prevatt
Technical Consultant
Currie Associates, Inc.
10 Hunter Brook Lane
Queensbury, NY 12804
Ref. No.: 12-0229
Dear Ms. Prevatt:
This responds to your October 1, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the closure instruction requirements in § 178.2(c)(1)(i)(B). Specifically you ask if the closure instructions that you included with your request meet the requirements of § 178.2(c)(1)(i)(B).
In accordance with § 178.2(c)(1)(i)(B) closure instructions must provide a consistent and repeatable means of closure necessary to ensure the packaging is closed in the same manner as it was tested. The HMR do not provide specific examples of acceptable closure processes because these methods will vary depending on the type of packaging used. Methods that provide the packaging assembler with instructions that are sufficient to prepare the packaging in the same manner as it was prepared prior to successfully passing the design qualification testing required in subpart M of part 178 would be considered acceptable. It is the opinion of this office that the terminology and level of detail provided in the packaging instructions that you provided are vague and would not provide a consistent and repeatable result that ensures the packaging is closed in the same manner as it was tested.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division
178.2