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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #99-0005 ([Package Research Laboratories] [Ms. Sue E. Pelletier-Bruno])

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

Interpretation Response Details

Response Publish Date:

Company Name: Package Research Laboratories

Individual Name: Ms. Sue E. Pelletier-Bruno

Location State: NJ Country: US

View the Interpretation Document

Response text:

March 22, 1999


Ms. Sue E. Pelletier-Bruno                Ref.  No:  99-0005
Package Research Laboratories
41 Pine Street
Rockaway, NJ 07866

Dear Ms. Pelletier-Bruno:

This responds to your letter of February 17, 1999, and your conversation with Ms. Diane LaValle of this office concerning requirements for testing specification packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask for confirmation that testing is not considered complete until a test report has been prepared, dated, and signed.

Your understanding is correct.  A test report must be completed for each packaging design qualification test and each periodic test.  Section 178.601(l) of the HMR sets forth the information that must be included in each test report.  The test report may not be signed and dated until all the required information is compiled and finalized.

Completion of a test report is the final step in the packaging design qualification testing or periodic retesting process; thus, no specification packaging may be manufactured for sale or use until a report documenting successful completion of all required tests has been completed.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.



Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.601 General requirements