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Interpretation Response #14-0137 ([Vonco Products, LLC.] [Mr. Keith E. Smith])

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

Interpretation Response Details

Response Publish Date:

Company Name: Vonco Products, LLC.

Individual Name: Mr. Keith E. Smith

Location State: IL Country: US

View the Interpretation Document

Response text:

October 29, 2014

Mr. Keith E. Smith
Vonco Products, LLC
201 Park Avenue
Lake Villa, IL 60046

Ref. No.: 14-0137

Dear Mr. Smith:

This is in response to your email dated July 15, 2014 and a follow-up telephone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to secondary packaging testing requirements for infectious substances. Specifically you ask whether for a triple packaging which has been successfully tested for transportation of a Category A infectious substance, a different secondary packaging may be substituted without further testing.

Section 173.196(a) provides that a packaging for a Category A infectious substance must meet the test standards of § 178.609. Section 178.609 does not authorize the substitution of a different secondary packaging without further testing. However, in accordance with Variation 3 found in § 178.609(i)(3), primary receptacles of any type may be placed within a secondary packaging and shipped without testing in the outer packaging provided all of the testing and requirements of § 178.609(i)(3) are met for both the secondary and outer packaging.

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


Shane C. Kelley
Acting International Standards Coordinator
Standards and Rulemaking Division
173.196(a), 178.609, 178.609(i)(3)

Regulation Sections

Section Subject
173.196 Category A infectious substances
178.609 Test requirements for packagings for infectious substances