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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 #18-0064

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

Interpretation Response Details

Response Publish Date:

Company Name: Ten-E Packaging Services

Individual Name: Robert Ten Eyck

Location State: MN Country: US

View the Interpretation Document

Response text:

February 25, 2019

Robert Ten Eyck 
Ten-E Packaging Services
1666 County Road 74
Newport, MN  55055

Reference No. 18-0064

Dear Mr. Ten Eyck:

This letter is in response to your March 21, 2018, email and subsequent conversations with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to closure requirements for shipments of receptacles being transported by aircraft.  Specifically, you ask if your client’s bottle design as described below meets the requirements of § 173.27(d) for secondary closures. 

You provide technical drawings of your client’s bottle design and further describe it as having a closure with an interlocking flange design that once connected to the bottle cannot be removed without destroying the closure or the bottle neck itself.  You also state that the closure incorporates an “anti-back off” feature similar to a child lock.  

After reviewing the description and technical drawings you provided, it is the opinion of this Office that the closure meets the closure requirements of § 173.27(d).

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

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division
173.27(d)

 

Regulation Sections