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

Interpretation Response #20-0010

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

Interpretation Response Details

Response Publish Date:

Company Name: AECOM Techincal Services

Individual Name: Andy Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

August 18, 2020

Andy Romach
Principal Scientist
AECOM Technical Services
1600 Perimeter Drive, Suite 400
Morrisville, NC  27560

Reference No. 20-0010

Dear Mr. Romach:

This letter is in response to your February 5, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to UN specification marks on packagings. You describe a scenario in which a 4G box is tested in two different configurations – one that includes gel packs and one that uses paper filler instead of gel packs. You believe that the use of the 4G box with different inner packagings does not qualify it as a different packaging, as provided in § 178.601(c)(4)(ii).

Specifically, you ask whether it is permissible to mark the packaging with a single marking that reflects the greater tested maximum gross mass to cover both packaging configurations, rather than choosing only one marking representative of the packaging based on the specific configuration (i.e., the type of cushioning material) used at the time of shipment.

The answer is no. In order to be excluded as a "different packaging" in accordance with § 178.601(c)(4)(ii), the inner packagings must be the only component that differs within the combination packaging. However, given that a gel pack does not meet the definition of an inner packaging (as it is not used to contain hazardous materials), the packaging variations you describe meet the definition of a different packaging. Therefore, in this instance, a single marking that attempts to cover both specifications is not appropriate.

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
178.601 General requirements