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Interpretation Response #98-0547 ([Partners in Compliance, Inc.] [Mr. Jay Johnson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Partners in Compliance, Inc.

Individual Name: Mr. Jay Johnson

Location State: NC Country: US

View the Interpretation Document

Response text:

JAN 12, 1998


Mr. Jay Johnson
Partners in Compliance, Inc.
100 Dominion Drive Suite 102
Morrisville, NC 27560

Dear Mr. Johnson:

This is in response to your letter of July 28, 1997, and August 11, 1997 telephone conversation with Ms. Eileen Edmonson of my staff asking if multiple primary packagings of a Division 6.2 material must be separated by a material that is both cushioning and capable of absorbing their entire contents.

The answer is no. Section 173 .196( a)(1 )(iii) requires that multiple primary packagings of a Division 6.2 material be wrapped individually by a material, absorbent or non-absorbent, sufficient to ensure contact between the receptacles is prevented and the packaging complies with the performance tests in § 178.609. However, this section require that material sufficient to absorb the entire liquid contents of the inner packagings be placed between the primary and secondary packagings.

You stated the current design for your packaging has each primary receptacle surrounded with an absorbent foam that prevents contact between the receptacles. You questioned whether separating these packagings with fiberboard or plastic dividers and placing an absorbent strip at the bottom of the secondary packaging would fulfill the requirements in § 173.196. Provided the packaging meets the performance tests required in § 178.609, this configuration would be acceptable. However, please be aware that these performance tests require the packaging to be dropped on its bottom, top, sides, and corner, cold-conditioned and immersed in water with no leakage from the primary receptacle. Placing the absorbent material only at the bottom of the packaging may prove insufficient to meet these criteria.

Thank you for inquiry. If we can assist you further, please let us know.



Hattie L. Mitchell, Chief
Exemptions and Regulations
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
173.196 Category A infectious substances