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Interpretation Response #17-0013 ([Berlin Packaging] [Gary Lindsey])

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

Interpretation Response Details

Response Publish Date:

Company Name: Berlin Packaging

Individual Name: Gary Lindsey

Location State: PA Country: US

View the Interpretation Document

Response text:

March 31, 2017

Gary Lindsey
Berlin Packaging, Dangerous Goods Division
1195 Washington Pike
Bridgeville, PA 15017

Reference No. 17-0013

Dear Mr. Lindsey:

This letter is in response to your February 1, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to certain packaging requirements for nitric acid. You reference § 173.158(e), which states that when nitric acid of less than 90 percent concentration is packed in wooden or fiberboard outer packagings, the glass inner packagings must be packed in tightly-closed, intermediate packagings and cushioned with an absorbent material. Specifically, you ask if the intent of this section is to require enough absorbent material to absorb the entire contents of the package.

The answer is yes. The requirement for absorbent material is such that there must be a sufficient amount to absorb the entire liquid contents of the package. This is consistent with similar requirements in other sections of the HMR.

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

173.158(e)

Regulation Sections

Section Subject
173.158 Nitric acid