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Interpretation Response #98-0373 ([Signode Packaging Systems] [Mr. Mark T. Hughes])

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

Interpretation Response Details

Response Publish Date:

Company Name: Signode Packaging Systems

Individual Name: Mr. Mark T. Hughes

Location State: IL Country: US

View the Interpretation Document

Response text:

FEB 10, 1998


Mr. Mark T. Hughes
Senior Packaging Research Engineer
Signode Packaging Systems
3640 West Lake Avenue
Glenview, Illinois 60025

Dear Mr. Hughes

This is in response to your letter, and telephone conversation with Diane LaValle of my staff, requesting clarification on the definition of non-bulk composite packagings regarding the use of flexible plastic woven bags under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Specifically, you describe a flexible woven plastic bag which has corrugated fiberboard sewn between the layers of woven material to provide rigidity and a 3 mil. plastic liner and ask if it may be described as a UN 6001 composite packaging (i.e., a plastic receptacle within a protective plastic drum).

The answer is no. A packaging certified as a UN 6001 must be constructed as provided in § 178.509 (Standards for plastic drums and jerricans). However, as provided in § 178.601(h), a packaging having specifications different from those in §§ 178.504-178.523 may be used if approved by the Associate Administrator for Hazardous Materials Safety. Such packagings must be shown to be equally effective and the testing methods used must be equivalent.

I hope this information is helpful.



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


Regulation Sections

Section Subject
171.8 Definitions and abbreviations