USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #20-0004

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

Interpretation Response Details

Response Publish Date:

Company Name: North American Automotive Hazmat Action Committee

Individual Name: Wayne Shafer

Location State: MI Country: US

View the Interpretation Document

Response text:

April 24, 2020

Wayne Shafer
Lead, Supplier Regulatory Workgroup
North American Automotive Hazmat Action Committee
4505 W. 26 Mile
Washington, MI  48094

Reference No. 20-0004

Dear Mr. Shafer:

This letter is in response to your January 22, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the testing of non-bulk packagings. Specifically, you ask whether a different cushioning material can be used than what was used in the originally tested specification packaging without having to retest the packaging.

The answer is no. Using a different cushioning material between the inner and outer packagings would qualify as a new packaging and thus require the packaging to be tested in accordance with Part 178, Subpart M.

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

Regulation Sections

Section Subject
178 SPECIFICATIONS FOR PACKAGINGS