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Interpretation Response #98-0043 ([Container-Quinn Testing Laboratories, Inc.] [Mr. Stephen C. Powell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Container-Quinn Testing Laboratories, Inc.

Individual Name: Mr. Stephen C. Powell

Location State: IL Country: US

View the Interpretation Document

Response text:

NOV 6, 1993


Mr. Stephen C. Powell                            Ref. No. 98-0043

Laboratory Manager
Container-Quinn Testing Laboratories, Inc.
170 Shepard Avenue
Wheeling, IL 60090

Dear Mr. Powell:

This is in response to your letter dated April 30, 1998, requesting clarification on certifying packages using corrugated materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you are requesting clarification on whether to use the Edge Crush Test (ECT) or Mullen Burst Test to certify various grades of corrugated packaging materials used in industry, and whether changing liners makes a "different packaging" for testing purposes.

Under the HMR a "different packaging" is broadly defined. As specified in § 178.601(c)(4), a packaging which differs in construction such as bursting strength, fluting, basis weight, etc. is considered a different packaging under § 178.601 (c) ( 4), and must be certified by undergoing design qualification testing. Packagings with different liner/medium combinations are differences in construction or design type and will require testing as a different packaging design. A packaging which differs only in surface treatment, e.g., color, is not considered to be a different design type under provisions of § 178.601(c)(4). The HMR does not require the use of the ECT in lieu ofthe Mullen Burst test for design qualification testing. Additional supporting information and statistical data on these tests must be provided to this office if you believe that one test in lieu of the other should be recommended for use in determining a "different packaging" or as a design qualification test. As provided in § 106.31, you may submit a petition for rulemaking on this matter.

I hope this answers your inquiry. If you need additional assistance, do not hesitate to contact me.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.601 General requirements