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Interpretation Response #15-0074 ([SGS North America, Inc.] [Mr. Jason Sherrier])

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

Interpretation Response Details

Response Publish Date:

Company Name: SGS North America, Inc.

Individual Name: Mr. Jason Sherrier

Location State: NJ Country: US

View the Interpretation Document

Response text:

July 09, 2015

Mr. Jason Sherrier
Laboratory Manager
SGS North America, Inc.
291 Fairfield Ave
Fairfield, NJ 07004

Reference No. 15-0074

Dear Mr. Sherrier:

This is in response to your April 13, 2015 e-mail request regarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of aluminum boxes. You note that you intend to offer a non-explosive PG III solid material in a 4B aluminum box. Specifically, you ask if a 4B aluminum box can be certified without a liner being present.

The answer to your question is yes. In accordance with § 178.512(b) as a part of their general design standards, aluminum boxes must be lined with fiberboard or felt packing pieces or must have an inner liner or coating of suitable material in accordance with subpart C of part 173 of this subchapter. The intent of the reference to subpart C of part 173 of the HMR is to ensure that these lining or coating requirements are applicable only to boxes intended to transport explosives. In your incoming email you reference a 52 FR 67403 rulemaking. There is no such Federal Register citation. Section 178.512 was amended by HM-215A (59 FR 67521) in December of 1994. The text provided in the preamble for proposed changes to § 178.512 in the HM-215A NPRM (59 FR 36498) states

"Standards for steel and aluminum boxes would be consolidated by removing the distinction between unlined/uncoated steel or aluminum boxes and steel or aluminum boxes having an inner liner or coating. Therefore, both unlined and lined steel boxes would be identified as 4A and unlined and lined aluminum boxes would be identified as 4B. Corresponding revisions would be reflected in the packaging authorizations of Part 173."

Existing non-bulk packaging authorizations (e.g. § 173.212) for certain hazardous materials will show single packaging authorizations for both "Aluminum box: 4B" and "Aluminum box with liner: 4B". If the non-bulk packaging requirements section referenced in column 8A for the material in question indicates an "Aluminum box: 4B" is an authorized single packaging the material may be offered in an aluminum box without a coating or liner.

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



Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division

178.512(b), 178.512, 173.212

Regulation Sections

Section Subject
173.212 Non-bulk packagings for solid hazardous materials in Packing Group II
178.512 Standards for steel, aluminum or other metal boxes