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Interpretation Response #13-0091

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

Interpretation Response Details

Response Publish Date: 07-31-2013
Company Name: Gh Package/Product Testing and Consulting, Inc.    Individual Name: Mr. Ronald J. Sorrell
Location state: OH    Country: US

View the Interpretation Document

Response text:

July 31, 2013



Mr. Ronald J. Sorrell
Gh Package/Product Testing and Consulting, Inc.
4090 Thunderbird Lane
Fairfield, OH 45014

Ref No.: 13-0091

Dear Mr. Sorrell:

This is a response to your April 30, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) with regard to the assembly of a UN 4G fiberboard box.  Specifically, you seek clarification on the criteria for passing the drop test specified in § 178.603.  

In your incoming email you describe a telescoping box with a loaded base and a top that slides over the base.  The box is assembled both with and without a band or tape around the girth of the closed packaging.  This packaging has been tested in accordance with the design qualification testing specified in Part 178 Subpart M and in both configurations successfully passed all required tests, including the drop test in § 178.603.  However, for the assembled box not secured by a band or tape around the girth, you observe that after the drop test, the top portion of the telescoping box is raised 2-3 inches with no release of product.  You question whether the raised lid after the drop test constitutes a closed packaging.

The answer is yes.  Provided there is no release of contents from the packaging and the packaging passes all applicable UN Specification tests, this would be permissible.  It should be noted that the standards for fiberboard boxes in § 178.516(b)(5) require that boxes must be designed so as to provide a snug fit to the contents.  The drop test described above may be an indication that the assembled box not secured by a band or tape around the girth does not meet the intent of § 178.516(b)(5).  

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

Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division


Regulation Sections

Section Subject
§ 178.516 Standards for fiberboard boxes