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 |