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Interpretation Response #98-0310 ([Law Offices of F. Michael Friedman] [Mr. F. Michael Friedman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Law Offices of F. Michael Friedman

Individual Name: Mr. F. Michael Friedman

Location State: PA Country: US

View the Interpretation Document

Response text:

NOV 13, 1998


Mr. F. Michael Friedman                     Ref. No. 98-0310
Law Offices of F. Michael Friedman
Post Office Box 1000
Media, Pennsylvania 19063-0790

Dear Mr. Friedman:

This is in response to your letter dated October 14, 1998 regarding clarification of the small quantity exceptions in 49 CFR 173.4, under the Hazardous Materials Regulation {HMR; 49 CPR Parts 171-180}.

Your questions are paraphrased and answered as follows:

Q1. The small quantity exceptions in 49 CPR 173.4 contain specific language describing the performance requirements for acceptable packaging; does this mean that it is not necessary to use UN standard packaging for materials offered for shipment under 49 CFR 173.4, provided the materials meet these requirements?

A1. Your understanding is correct. A material prepared in accordance with the quantity limits and packaging requirements in 49 CFR 173.4, is not subject to any other requirements of the HMR, including UN standard packaging requirements.

Q2. Is there a periodic retest requirement for packages used for hazardous material shipments made in accordance with 49 CFR 173.4.

A2. No. Only prototype testing of a packaging is required.

However, if the packaging is modified, a new prototype test must be performed. As provided in § 173.4(a) (6), each completed packaging must be capable of passing the prescribed tests.
I hope this satisfies your inquiry.



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


Regulation Sections

Section Subject
173.4 Small quantities for highway and rail