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Interpretation Response #98-0502 ([Department of the Army] [Ms. Marcia C. Davies, Ph.D])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of the Army

Individual Name: Ms. Marcia C. Davies, Ph.D

Location State: N Country: US

View the Interpretation Document

Response text:

APR 9, 1998


Ms. Marcia C. Davies, Ph.D.
Department of the Army
Corps of Engineers
Omaha District HTRW Center of Expertise
12565 West Center Road
Omaha, Nebraska 68144-3869

Dear Dr. Davies:

This is in response to your letter of March 4, 1998, requesting clarification of the packaging requirements for small quantities of hazardous materials under the Hazardous Materials Regulations (49 CFR parts 171-180). Specifically you ask whether the prototype testing required by § 173.4(a)(6) requires each test to be performed on the same packaging.

The answer is no. As you pointed out in the original HM~181 final rule (55 FR 52402) § 173.4 has a note which states "Each of the test in paragraph (a)(6) of this section may be performed on a different but identical package; i.e., all tests need not be performed on the same package. n Therefore, the intention of this section is that you may perform each test on a different package. This point will be clarified in a future rulemaking.

I hope this information is helpful.



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

Regulation Sections

Section Subject
173.4 Small quantities for highway and rail