{"operation":"document","citation":"00-0138","title":"Corrugated Container Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-06-28","effective_on":null,"summary":"00-0138 response to Corrugated Container Corporation concerning 178.601.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0138.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0138.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0138","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000138.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\n400 Seventh Street, S.W.\nof Transportation\nWashington, D.C.\n20590\nResearch and\nSpecial Programs\nAdministration\nJUN 2 8 2000\nMr. John Byers\nRef. No. 00-0138\nCorrugated Container Corporation\nPO Box 20369\nRoanoke, VA 24018\nDear Mr. Byers:\nThis is in response to your letter dated May 5, 2000, and subsequent telephone conversation with Eric\nNelson of my staff requesting clarification of marking requirements for UN standard packagings under\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the date\nwhen periodic retesting is required for a combination packaging is two years from the date of\nmanufacture or the date of the original design qualification test.\nThe answer is the date of the original design qualification test. A combination or composite packaging\nmay be marked as being \"manufactured\" on the date on which the packaging was assembled.\n\"Assembly\" is the physical act of placing inner packagings or a liner into an outer packaging. It is\nimportant to note here that the date of a design qualification test or periodic retest and the date of\nmanufacture are two different things. The date marked on the packaging does not necessarily reflect\nthe date the packaging was tested.\nFor example, a combination packaging that is tested in January 1998 may be manufactured anytime\nwithin 24 months after that test, and dated the year it is manufactured, which would be 1998, 1999, or\n2000; or the packaging may be dated the year it is assembled, which could be any year thereafter.\nAside from the date the packaging is assembled, the packaging design must be retested by the end of\nJanuary, 2000.\nI hope this satisfies your request.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n178.60)\n000138\n\n<<<PAGE 2>>>\n\nMay\nUUs\n- O\n(78.60)\nNelson\n00-0138\nCorrugated Container Corporation\nDate:\nFriday, May 05, 2000\nvisit us at www.cccbox.com\nTo:\nHazardous Information Department Dot\nFo Puzzullo\nJoan Macintire\nPhone:\n2026068 it. B\nFax:\n202-366-3012\nFrom:\nCorrugated Container Corp.\nJohn Byers\nPhone:\n540-774-0547, Ext 208\nEmail:\njbyers@cccbox.com\nFax:\n540-774-2142\nPager\n888-594-1743\nHome Fax\n435-808-2028\nPages:\nSubject:\nRecertification date confirmation\nI spoke with Mindy in your office about 2 months ago, and Joan MacIntire this morning. I need a\ncombination 4G pack certified by a test lab in March of 98. The application tested was a small user, and\nclarification of Mind's information in writing on the following situation. My customer had a\na production order was not entered until November of 98(8 months later). According to Mindy the date\n\"to use for recertification is the date of manufacture, not the test date. Please clarify and fax back to me\nasap. Thanks in advance for your assistance.\n10369\npo Box\nRoanoke VA 24018","truncated":false,"body_characters":2850}