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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)

Regulation Sections

Section Subject
173 SHIPPERS-GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS
173.24 General requirements for packagings and packages
178.608 Vibration standard