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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 #13-0187 ([Westpak, Inc.] [Mr. Pal Khangaldy])

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

Interpretation Response Details

Response Publish Date:

Company Name: Westpak, Inc.

Individual Name: Mr. Pal Khangaldy

Location State: CA Country: US

View the Interpretation Document

Response text:

November 26, 2013

Mr. Pal Khangaldy
Director of Engineering
Westpak, Inc.
83 Great Oaks Blvd.
San Jose, CA  95119

Ref. No.: 13-0187

Dear Mr. Khangaldy:

This is in response to your September 6, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to combination packages.  In your scenario, you state that two similar combination packages are tested and certified as performance oriented packages with different inner packagings.  You ask whether it is acceptable to mix the two types of inner packagings in the combination packages provided they not exceed the weight rating of the package system and all materials in the package are compatible.

The answer to your question is yes.  In accordance with § 178.601(c)(4), a “different packaging” is defined as one that differs from a previously produced packaging in structural design, size, material, of construction, wall thickness or manner of construction.  However,     § 178.601(c)(4)(ii) states that this definition does not include a combination packaging which differs only in that the outer packaging has been successfully tested with different inner packagings.  This definition permits a variety of inner packagings to be assembled in the outer packaging without further testing.

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
178.601 General requirements