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Interpretation Response #98-0284 ([The Boeing Company] [Mr. Scott Chapman])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Boeing Company

Individual Name: Mr. Scott Chapman

Location State: CA Country: US

View the Interpretation Document

Response text:

NOV 16, 1998


Mr. Scott Chapman                          Ref. No. 98-0284
The Boeing Company
Airline Logistics Support
Dept. P62, MC:DOC6-0021
3855 Lakewood Boulevard
Long Beach, California 90846-0001

Dear Mr. Chapman:

This is in response to your letter of September 17, 1998 requesting clarification of the requirements for certification of a UN standard packaging under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Your questions are paraphrased and answered as follows:

Q1. A packaging is tested and certified to a UN standard. The materials of construction are now purchased from a different manufacturer than the originally tested packaging. Must the packagings now be tested and certified as a different packaging?

A. If the materials of construction are virtually identical to the materials in the originally tested packaging no new testing is required. For example, fiberboard that is manufactured by different companies but has identical burst strength, fluting, basis weight, edge crush, etc. may be used interchangeably in a packaging without any further testing regardless of who actually manufactures the materials.

Q2. A facility uses a test report to identify the specifications of the materials of construction requested from a manufacturer and specifies that it is mandatory that the materials of construction have exact or better physical properties. Who is responsible for ensuring that the materials of construction actually meet these standards?

A. Whoever is identified on the packaging as the manufacturer has the responsibility to ensure that the packaging meets the UN standard to which it is certified.

Q3. May the materials of construction be different from the originally tested design type if the materials of construction have stronger properties than those originally tested?

A. The answer is no. Unless it can be ascertained that the materials of construction are virtually identical it is considered a new packaging and subject to design qualification testing.

Q4. If a facility: (1) qualifies a design to a UN standard; (2) documents the packaging design; (3) submits to RSP A a detailed operating procedure outlining procurement and controlled Quality Assurance program could they be granted relief from the periodic retesting requirements of § 178.601(e)?

A. As provided by § 178.601(h) a packaging that is tested using test intervals other than those specified in Subpart M of Part 178 may be used if approved by the Associate Administrator for Hazardous Materials Safety. Instructions for applying for an approval are described in § 107.705.

I hope this information is helpful.



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


Regulation Sections

Section Subject
178.601 General requirements