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Interpretation Response #15-0125 ([Westpak, Inc.] [Mr. Jorge Campos])

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. Jorge Campos

Location State: CA Country: US

View the Interpretation Document

Response text:

November 25, 2015

Mr. Jorge Campos
Westpak, Inc.
83 Great Oaks Drive
San Jose, CA 95119

Reference No. 15-0125

Dear Mr. Campos:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to package testing requirements for a pressurized "keg." In your letter you state that the "keg" is intended to contain 18 liters of "UN3082, Environmentally Hazardous Substance, 9, III" and 2 liters of nitrogen gas. The "keg" is filled with a vacuum system and pressurized to 10 psi. It is your understating that because the nitrogen gas does not exceed a gauge pressure of 200 kPa (43.8 psia), the material contained in the "keg" does not meet the definition of a Division 2.2 material, and as such, the keg does not need to be tested as a single packaging. In addition, you request confirmation that the testing requirements for combination packages may be applied with the "keg" being the inner package and a fiberboard box being the outer package.

In the scenario described the "keg" may be considered an inner packaging of a combination package. As the nitrogen gas contained in the "keg" does not meet the definition of a Division 2.2 material a specification inner packaging prescribed for gases is not required. The completed packaging may be considered a combination package and may tested in accordance with Subpart M of Part 178 for a packaging authorized in § 173.203.

I hope this information is helpful.



Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.203 Non-bulk packagings for liquid hazardous materials in Packing Group III