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Interpretation Response #99-0125 ([Bell Helicopter TEXTRON] [Mr. Albert Alva])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bell Helicopter TEXTRON

Individual Name: Mr. Albert Alva

Location State: TX Country: US

View the Interpretation Document

Response text:

August 10, 1999


Mr. Albert Alva                             Ref No. 99-0125
Bell Helicopter TEXTRON
Post Office Box 482
Forth Worth, Texas 76101

Dear Mr. Alva:

This is in response to your letter dated March 13, 1999, regarding whether your understanding is correct that under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) an existing fiberboard box (UN 4G) may be retaped with your company's tape.

You stated that your company, Bell Helicopter, receives numerous hazardous materials in UN 4G fiberboard boxes from various manufacturers, which are opened and inspected and then retaped and shipped to another customer.  The inner packagings and cushioning material, if present, is not changed or altered.

Under the notification provision of 49 CFR 178.2(c), the manufacturer and each subsequent distributor of a UN packaging must provide written instructions to customers of all regulatory requirements not met at time of transfer, such as instructions on how to properly assemble and close a packaging (e.g., UN 4G fiberboard box).  Therefore, the tape used to reclose a package that has been opened must be the type specified in the closing instructions.  In addition, the package may not be damaged by original opening.

There is no limitation on who may reuse a packaging for the transportation of hazardous materials.  The person who reuses the packaging does not have to be the original user.  The reuse provisions in 49 CFR 173.28 must be met for a packaging manufactured to a UN standard (e.g.,UN 4G). A UN 4G fiberboard box may be reused subject to the conditions and limitations of that section.

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.



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


Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings