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Interpretation Response #98-0515 ([Autoliv ASP, Inc.] [Mr. Terry Zost])

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

Interpretation Response Details

Response Publish Date:

Company Name: Autoliv ASP, Inc.

Individual Name: Mr. Terry Zost

Location State: UT Country: US

View the Interpretation Document

Response text:

MAY 14 1998


Mr. Terry Zost
Manager, Logistics Services
Autoliv ASP, Inc.
3350 Airport Road
Odgen, Utah 84405

Dear Mr. Zost:

This is in response to your letter dated January 21, 1998, regarding the definition of an overpack. Specifically, you ask if two or more packages are considered overpacked if they are secured to a wooded pallet by metal or composite banding.

The Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) define an overpack in § 171.8 as an enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages. Section 171.8 provides the following examples of overpacks: (.1) one or more packages placed or stacked onto a board such as a pallet and secured by strapping, shrink wrapping, stretch wrapping or other suitable means; or (2) one or more packages placed in a protective outer packaging such as a box or a crate. It is the opinion of this Office that the packaging scenario provided in your letter constitutes an overpack in accordance with both the HMR and the International. Civil Aviation Organization's Technical Instructions for the Transport of Dangerous Goods by Air.

I hope this satisfies your request.



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

Regulation Sections

Section Subject
173.25 Authorized packagings and overpacks