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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 #98-0336 ([Ms. Britt-Marie Butler])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Ms. Britt-Marie Butler

Country: SE

View the Interpretation Document

Response text:

JAN 14, 1999


Ms. Britt-Marie Butler             Reference No. 98-0336

Husqvarna AB

S-433 81 Jonsered SWEDEN

Dear Ms. Butler:

This is in response to your letter asking if your packaging, a 6-liter UN 3H1 non-removable head plastic jerrican pin-mounted (joined) to a non-specification 2.5 liter plastic blow-molded bottle, would qualify as a combination packaging in the United States.

The answer is no. As defined in 49 CFR 171.8, a combination packaging means one or more inner packagings secured in a non-bulk outer packaging; a condition your joined packagings do not meet. Instead, your jerrican meets the definition in § 171.8 for a single packaging and must be tested and approved in accordance with the UN specification requirements. Because the packagings are pin-mounted, we also recommend that they be drop tested separately and after being joined together.

I hope this satisfies your request.



Edward T. Mazzullo Director,

Office of Hazardous Materials Standards

178.509, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
178.509 Standards for plastic drums and jerricans