Interpretation Response #15-0154 ([Inmark Packaging, Inc.] [Mr. Jay Johnson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Inmark Packaging, Inc.
Individual Name: Mr. Jay Johnson
Location State: GA Country: US
View the Interpretation Document
Response text:
February 1, 2016
Mr. Jay Johnson
Regulatory Compliance Manager
Inmark Packaging, Inc.
675 Hartman Road, Suite 100
Austell, GA 30168
Ref. No.: 15-0154
Dear Mr. Johnson:
This is in response to your July 27, 2015 email and subsequent telephone conversation with a member of my staff concerning packaging requirements for Category B infectious substances contained in the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). Specifically, you ask whether a Category B packaging is required to meet the conditions specified in §§ 178.609(e) and 178.609(f) for water spray and cold conditioning, respectively, before subjecting the packaging to the drop test in § 178.609(d).
As specified in § 173.199(a)(4), a Category B packaging must be capable of successfully passing the drop test in § 178.609(d) at a drop height of at least 1.2 meters (3.9 feet) but is not required to be tested using this method. Further, as stated in the preamble to a final rule issued under Docket No. PHMSA-2004-16895 (71 FR 32244), a § 173.199 packaging need not be capable of passing a puncture or other performance tests. Therefore, the HMR do not require that a Category B infectious substance packaging be subjected to the conditions prescribed in §§ 178.609(e) and 178.609(f) in preparation for the drop test prescribed in § 178.609(d).
I hope this information is helpful. Please contact this office if we can be of further assistance.
Sincerely,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
178.609(e), 178.609(f), 178.609(d), 173.199(a)(4), 173.199