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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #13-0017 ([Inmark Packaging] [Mr. Jay Johnson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Inmark Packaging

Individual Name: Mr. Jay Johnson

Location State: GA Country: US

View the Interpretation Document

Response text:

April 5, 2013



Mr. Jay Johnson
Regulatory Compliance
Inmark Packaging
675 Hartman Road, Suite 100
Austell, GA 30168

Ref. No.: 13-0017

Dear Mr. Johnson:

This is in response to your January 18, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) concerning the testing of specification packagings.  Specifically you seek confirmation of your understanding that variation 2 found in § 178.601(g)(2) permits the testing of a package with a single large inner packaging and substitution of multiple smaller inner packagings without retesting.

Your understanding is correct.  Variation 2 permits articles or inner packagings of any type for solids or liquids to be assembled and transported without testing in an outer packaging provided all of the conditions of § 178.601(g)(2) are met.  In the case you describe, if a single large fragile inner packaging containing liquids is placed into the outer package and subjected to the required drop test then multiple smaller inner packagings may be substituted for the single large inner packaging without retesting.  This is only permitted if the total combined gross mass of the smaller inner packagings does not exceed one-half the gross mass of the large inner packaging used for the original drop test and the thickness of the cushioning material is maintained.  Note, the inner and outer packagings must meet also the remaining requirements in § 178.601(g)(2) as appropriate.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.


Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
178.601 General requirements