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.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
173.25(b)
Regulation Sections
| Section | Subject |
|---|---|
| 173.25 | Authorized packagings and overpacks |