Interpretation Response #19-0112
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Jaycox Consulting
Individual Name: Lonnie Jaycox
Location State: MO Country: US
View the Interpretation Document
Response text:
January 21, 2020
Lonnie Jaycox
Independent Consultant
Jaycox Consulting
4027 Magnolia Avenue
Saint Louis, MO 63110
Reference No. 19-0112
Dear Mr. Jaycox:
This letter is in response to your September 3, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to combination packagings. Specifically, you ask whether articles that are placed in a non-bulk outer packaging—such as a 4G box—without additional inner packagings, may be tested and certified as a combination packaging.
The answer is no. A combination packaging must be comprised of an inner packaging that is secured in a non-bulk outer packaging. Articles are not considered inner packagings and, therefore, their presence inside of a non-bulk outer packaging—such as a 4G box—would be insufficient for certification as a combination packaging.
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