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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 #18-0055

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

Interpretation Response Details

Response Publish Date:

Company Name: Alden Medical LLC

Individual Name: Mr. Chris Corridn

Location State: MA Country: US

View the Interpretation Document

Response text:

August 28, 2018

Mr. Chris Corridan
Alden Medical LLC
360 Cold Spring Avenue
West Springfield, MA  01089

Reference No. 18-0055

Dear Mr. Corridan:

This letter is in response to your April 9, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of United Nations (UN) specification packaging.  You explain that your company has UN specification packagings that underwent performance testing by a certified third party facility, and the resulting test report suggested a periodic retest date of every 24 months.  Specifically, you ask if you can continue to use a packaging beyond the periodic retest date provided no changes are made to the approved packaging design.

The answer is yes.  An unused UN certified packaging can be manufactured, maintained in inventory for an indefinite amount of time, and then used without being retested.  There are no retesting procedures that a shipper must conduct for an unused UN certified packaging.  The periodic retest procedures described in § 178.601(e) are design requalifications that must be performed by the manufacturer to demonstrate that their design types still pass performance tests.

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



Regulation Sections

Section Subject
178.601 General requirements