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Interpretation Response #98-0341 ([Bell Container Corporation] [Ms. Elaine Walicky])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bell Container Corporation

Individual Name: Ms. Elaine Walicky

Location State: NJ Country: US

View the Interpretation Document

Response text:

JAN 11, 1999


Ms. Elaine Walicky                            Ref No. 98-0341
Sales and Administrative Services
Bell Container Corporation
615 Ferry Street
Newark, NJ 07105

Dear Ms. Walicky:

This is in response to your letter of November 13, 1998, requesting clarification of the requirements for manufacturing UN standard packagings under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180).  Specifically you ask whether you may reproduce a packaging that was originally manufactured by a different company as long as you reproduce the exact specifications listed on the

Generally, no; if any component of a packaging differs in any way from the packaging that was originally design certified, the packaging is a "different packaging" as defined in § 178.601(c)(4) and must be retested.  An exception would be where the manufacturer can establish that the packaging is virtually identical (for example fiberboard must have the same burst strength, edge crush resistance, water absorption rate, board weight, manner of construction etc.). In addition, as provided by § 178.601 (1) the test report for each packaging must be maintained at each location where the packaging is manufactured and each location where the periodic retests are conducted until such tests are successfully performed again and a new test report is produced.

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