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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 #19-0060

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

Interpretation Response Details

Response Publish Date:

Company Name: Daniels Training Services, Inc.

Individual Name: Daniel Stoehr

Location State: IL Country: US

View the Interpretation Document

Response text:

September 17, 2019

Mr. Daniel Stoehr
Daniels Training Services, Inc.
P.O. Box 1232
Freeport, IL  61032-1232

Reference No. 19-0060

Dear Mr. Stoehr:

This letter is in response to your May 7, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the testing of non-bulk packages. Specifically, your email asks for clarification of the non-bulk packaging filling limits in § 173.24a(b). You note that § 173.24a(b)(3) reads "A non-bulk packaging not exceeding 400 kg which is tested and marked for liquid hazardous materials may be filled with a solid hazardous material to a gross mass, in kilograms, not exceeding the rated capacity of the packaging in liters, or gross mass of the package, multiplied by the specific gravity or gross mass of the package marked on the packaging, or 1.2 if not marked." You seek clarification on the term "gross mass of the package." You ask whether the formula in § 173.24a(b)(3) allows for a shipper to multiply the actual gross mass of the package by the gross mass marked on the package to achieve a total value that may exceed the actual gross mass of the package.

The answer is no. The intention of § 173.24a(b)(3) is for a shipper to multiply the rated capacity of the package by the marked specific gravity and fill to a maximum of that calculated mass, in kilograms, or the 400 kg maximum, whichever is less. PHMSA may provide further clarification of this section in a future rulemaking action.

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

173.24a(b), 173.24a(b)(3)

Regulation Sections

Section Subject
173.24 General requirements for packagings and packages