Interpretation Response #98-0535 ([Hodgdon Powder Co., Inc.] [Mr. Ben Barrett, P. E.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hodgdon Powder Co., Inc.
Individual Name: Mr. Ben Barrett, P. E.
Location State: KS Country: US
View the Interpretation Document
Response text:
MAY 6, 1998
Mr. Ben Barrett, P. E.
Production & Regulatory Administrator
Hodgdon Powder Co., Inc.
Post Office Box 2932
Shawnee Mission, KS 66201
Dear Mr. Barrett:
This is in response to your letter dated October 15, 1997, requesting larification of the requirements in § 173 .171 (d), under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Your questions crre paraphrased and answered as follows:
Q1. Can a box tested for one inner package be used without further performance oriented packagings (POP) testing far other inner packages regardless of volume, shape, or materials of construction?
A1. Section 173 .171 (d) authorizes the intermixing of different inner packaging of tested and approved combination packaging with no further POP testing provided: (1) a 4G fiberboard packaging meeting the Packing Group I performance level is used; (2) all inside containers are packed to prevent movement; and (3) the total net weight of the material (i.e., smokeless powder) in one package does not exceed 16 pounds. In addition, several packages meeting the conditions of § 173.171 (d) may be overpacked together if the 100 pound net mass limitation in § 173 .171 (b) is not exceeded.
Q2. Can an intermediate packaging (i.e., fiberboard dividers) of a combination packaging be changed without further testing provided, the box is filled with packing material to prevent movement?
A2. The answer is no. Any change to the originally produced packaging in structural design, size, material of construction, wall thickness or manner of construction would result in a different packaging design type, and a different design type requires qualification testing.
Q3. Can any variance from the manufacturer's method of closing be allowed?
A3. The answer is no. Any change to the originally tested closure of a combination package authorized in § 173.171 would result in a different packaging design type, and a different design type requires qualification testing.
If we can be of further assistance, please feel free to contact us.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
Regulation Sections
| Section | Subject |
|---|---|
| 173.171 | Smokeless powder for small arms |