USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

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

Interpretation Response #13-0175 ([Sigma-Aldrich] [Ms. Leigh Davidson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sigma-Aldrich

Individual Name: Ms. Leigh Davidson

Location State: MO Country: US

View the Interpretation Document

Response text:

October 24, 2013

 

Ms. Leigh Davidson
Regulatory Affairs Attorney
Sigma-Aldrich
545 South Ewing Avenue
St. Louis, MO 63103

Reference No.: 13-0175

Dear Ms. Davidson:

This is in response to your August 23, 2013 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You ask several questions pertaining to metal receptacles when used as an inner receptacle in a combination packaging.

Your questions are paraphrased and answered as follows:

Q1. What are the requirements for a container to be acceptable as a metal receptacle when used as an inner packaging in a combination packaging?

A1. Both the inner packaging and the completed combination packaging must comply with the general packaging requirements in §§ 173.24 and 173.24a as applicable. If offered for air transportation, the package must also comply with the requirements of § 173.27.

Q2. May a DOT specification cylinder be used as an inner metal receptacle of a UN tested combination packaging provided a metal receptacle is authorized as an inner packaging in Part 173?

A2. The answer is yes.  A DOT specification cylinder may be used as an inner receptacle of a combination packaging provided the outer packaging has been successfully tested with the DOT specification cylinder or similar packaging as an inner receptacle.

Q3. May a non-DOT specification cylinder (i.e., one that has no specification marking, is beyond its requalification date, or approved by a foreign authority) be used as an inner metal receptacle of a UN tested combination packaging provided a metal receptacle is authorized as an inner packaging in Part 173 when transported in the United States?  

A3. The answer is yes.  A non-DOT specification cylinder may be used as an inner receptacle of a combination packaging provided the outer packaging has been successfully tested with the non-DOT specification cylinder or similar packaging as an inner receptacle.  

In addition, a cylinder that is marked to certify that it conforms to the requirements of Part 178 must be maintained in accordance with applicable specification requirements in the HMR whether or not it contains a hazardous material.  If the owner of the DOT specification cylinder wishes to continue to use the cylinder but does not wish to re-qualify the cylinder, the owner must obliterate or cover any specification markings whether or not it is being used to transport hazardous materials in commerce.
  
I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.24, 173.24a, 173.27

Regulation Sections

Section Subject
173.24 General requirements for packagings and packages
173.24a Additional general requirements for non-bulk packagings and packages