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Interpretation Response #19-0012

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

Interpretation Response Details

Response Publish Date:

Company Name: Military Surrface Deployment and Distibution Command

Individual Name: Jeffrey Leitschuh

Location State: IL Country: US

View the Interpretation Document

Response text:

June 03, 2019

Jeffrey M. Leitschuh
Hazmat/Transportation Safety Manager
Military Surface Deployment and Distribution Command
1 Soldier Way, Bldg 1900W
Scott AFB, IL 62225

Reference No. 19-0012

Dear Mr. Leitschuh:

This letter is in response to your February 5, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the design qualification testing of a packaging used for infectious substances. Specifically, you request clarification of the conditioning requirements for test samples in §§ 178.609(f), 178.603(c)(1), 178.810(b)(4), and 178.965(c) as they apply to a Category A packaging constructed of plastic. You interpret the conditioning requirements in § 178.609(f) to be the same as those specified in §§ 178.603(c)(1), 178.810(b)(4), and 178.965(c). The conditioning period as stated in § 178.609(f) must be sufficient to ensure that the test sample (the packaging and its contents) has been reduced to -18 °C or lower prior to performing the drop test. You interpret the phrase "a period of at least 24 hours" to be the minimum required amount of time for conditioning the test sample. In addition, your understanding is the conditioning period must continue past 24 hours if the test sample has not been fully reduced to -18 °C or lower at the end of the initial 24-hour conditioning period.

You are correct that testing of packages under § 178.609(f) requires a period of 24 hours for conditioning a test sample at -18 °C or lower. You are also correct that the conditioning period under § 178.609(f) would continue past 24 hours if the test sample has not been fully reduced to -18 °C or lower. However, such a time is not specified in §§ 178.603(c)(1), 178.810(b)(4), and 178.965(c). Packages tested under these sections of the HMR must have the test samples fully reduced to -18 °C or lower, but there is no specified minimum time frame for doing so.

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

178.609(f), 178.603(c)(1), 178.810(b)(4), 178.965(c)

Regulation Sections

Section Subject
178.603 Drop test
178.609 Test requirements for packagings for infectious substances
178.965 Drop test