Interpretation Response #19-0113
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Pristine World Academy
Individual Name: Sean Kelly
Location State: FL Country: US
View the Interpretation Document
Response text:
January 23, 2020
Sean Kelly
Pristine World Academy
1811 Laser Court
Fernandina Beach, FL 32034
Reference No. 19-0113
Dear Mr. Kelly:
This letter is in response to your September 3, 2019, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the packaging testing requirements for a limited quantity package via highway transportation. Specifically, you ask whether a packaging used for a limited quantity shipment by highway is subject to vibration test requirements in § 178.608.
The answer is no. In accordance with the applicable limited quantity requirements in Part 173, a limited quantity package transported by highway is excepted from the specification packaging requirements, including the vibration standard in § 178.608. However, in accordance with § 173.24a(a)(5), a packaging used for a limited quantity package must be capable of withstanding, without rupture or leakage, the vibration test procedure specified in § 178.608. Meeting this requirement may be based on performance of the test, institutional knowledge, prior experience, modeling, or other data.
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
178.608, 173, 173.24a(a)(5)