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 #13-0201 ([Hedwin Corporation] [Ms. Cheryl Defelice])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hedwin Corporation

Individual Name: Ms. Cheryl Defelice

Location State: MD Country: US

View the Interpretation Document

Response text:

January 27, 2014

Ms. Cheryl Defelice
Hedwin Corporation
1600 Roland Heights Avenue
Baltimore, MD   21211

Ref. No. 13-0201

Dear Ms. Defelice:

This responds to your October 25, 2013 request for clarification on the periodic retesting requirements for a 4GV non-bulk combination packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, your 4GV non-bulk combination packaging has been selectively tested under Variation 1 specified in § 178.601(g)(1).  You seek further clarification on a previously issued letter of interpretation (Ref No 08-0310) as it relates to your packaging.

Your questions are paraphrased and answered as follows:

Q1.  Is it necessary to conduct a periodic retest on each closure method that was previously tested during the design qualification test for the 4GV combination packaging?

A1.  The answer is no.  You may maintain a single test record and report identification number for identical packaging that differ only in method of closure, provided each method of closure is documented in the test report and the packaging successfully passes the required tests when closed in accordance with each closure method identified in the test report.  Selective testing of combination packaging under Variation 1 is authorized for 4GV combination packaging in accordance with § 178.601(g)(1).

Q2.  Is it possible to test just one of the closure methods documented in the report?

A2.  The answer is yes.  In accordance with Variation 1 in § 178.601(g)(1) selective testing is permitted provided inner closures are of similar design and an equivalent level of performance is maintained.  

I hope this answers your inquiry.  If you need additional assistance, please call this office at (202) 366-8553.


Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
178.601 General requirements