Corrugated Container Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Research and Special Programs Administration JUN 2 8 2000 Mr. John Byers Ref. No. 00-0138 Corrugated Container Corporation PO Box 20369 Roanoke, VA 24018 Dear Mr. Byers: This is in response to your letter dated May 5, 2000, and subsequent telephone conversation with Eric Nelson of my staff requesting clarification of marking requirements for UN standard packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the date when periodic retesting is required for a combination packaging is two years from the date of manufacture or the date of the original design qualification test. The answer is the date of the original design qualification test. A combination or composite packaging may be marked as being "manufactured" on the date on which the packaging was assembled. "Assembly" is the physical act of placing inner packagings or a liner into an outer packaging. It is important to note here that the date of a design qualification test or periodic retest and the date of manufacture are two different things. The date marked on the packaging does not necessarily reflect the date the packaging was tested. For example, a combination packaging that is tested in January 1998 may be manufactured anytime within 24 months after that test, and dated the year it is manufactured, which would be 1998, 1999, or 2000; or the packaging may be dated the year it is assembled, which could be any year thereafter. Aside from the date the packaging is assembled, the packaging design must be retested by the end of January, 2000. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 178.60) 000138#

Page 2May UUs - O (78.60) Nelson 00-0138 Corrugated Container Corporation Date: Friday, May 05, 2000 visit us at www.cccbox.com To: Hazardous Information Department Dot Fo Puzzullo Joan Macintire Phone: 2026068 it. B Fax: 202-366-3012 From: Corrugated Container Corp. John Byers Phone: 540-774-0547, Ext 208 Email: jbyers@cccbox.com Fax: 540-774-2142 Pager 888-594-1743 Home Fax 435-808-2028 Pages: Subject: Recertification date confirmation I spoke with Mindy in your office about 2 months ago, and Joan MacIntire this morning. I need a combination 4G pack certified by a test lab in March of 98. The application tested was a small user, and clarification of Mind's information in writing on the following situation. My customer had a a production order was not entered until November of 98(8 months later). According to Mindy the date "to use for recertification is the date of manufacture, not the test date. Please clarify and fax back to me asap. Thanks in advance for your assistance. 10369 po Box Roanoke VA 24018#