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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #15-0233 ([Inmark Packaging] [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

Individual Name: Mr. Jay Johnson

Location State: GA Country: US

View the Interpretation Document

Response text:

August 10, 2016

Mr. Jay Johnson, DGSA
Regulatory Compliance Manager
Inmark Packaging
675 Hartman Road, Suite 100
Austell, GA  30168

Reference No. 15-0233

Dear Mr. Johnson:

This letter is in response to your email and subsequent telephone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the selective testing of a combination package.  Specifically, you request clarification of the application of Variation 4 in combination with Variation 1 found under
§ 178.601(g) of the HMR.

In your email, you state that you have a United Nations (UN) 4G combination packaging design successfully tested by an approved third party lab consisting of 4 x 1 gallon bottles in an outer fiberboard box.  You intend to reduce the number of bottles by half and the size of the fiberboard box as authorized under Variations 1 and 4 of the selective testing provisions in       § 178.601(g)(1) and (g)(4), respectively.  You ask whether the marked gross mass on the packaging design should remain as originally certified or whether it should be reduced in proportion to the reduction in the number of inner packagings and the reduction in outer packaging dimensions.

As prescribed in § 178.601(g), variations that differ only in minor respects of a tested design-type are permitted without further testing.  However, unlike Variation 3 in § 178.601(g)(3), when using Variations 1 or 4, or a combination of both, reducing the marked gross mass is not necessary provided an equivalent level of performance is maintained in accordance with the original design, i.e., the packaging must be capable of passing the Part 178, Subpart M performance tests commensurate with the marked gross mass.

I hope this information is helpful.  Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
178.601(g), 178.601(g)(1)

Regulation Sections

Section Subject
178.601 General requirements
178.601 General requirements