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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.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject