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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 #16-0160 ([URS Corporation] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: URS Corporation

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

March 31, 2017

Andrew Romach
Regulatory Compliance Manager
URS Corporation
1600 Perimeter Park Drive
Suite 400
Morrisville, NC 27560

Reference No. 16-0160

Dear Mr. Romach:

This letter is in response to your September 30, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to aerosol cans on shrink-wrapped trays. Specifically, you ask whether it is acceptable to ship aerosol cans under the provisions of § 173.25(b) if the cans are shrink-wrapped together and glued to a tray without using additional shrink-wrap to hold both the cans and tray in place.

The answer is no. In order to use a tray as an outer packaging in accordance with § 173.25(b), the inner packagings (in this scenario, the aerosol cans) must be shrink-wrapped or stretch-wrapped to the tray.

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



Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
173.25 Authorized packagings and overpacks