Defense Logistics Agency — Hazardous Materials Safety Interpretation

Page 1• U.S. Department of Transportation 400 Seventh St., S.W. Research and Washington, D.C. 20590 ›pecial Programs Idministration JUL 16 2001 Ms. Linda McCarthy Defense Logistics Agency • Ref. No. 00-0320 2001 Mission Drive New Cumberland, PA 17070-5000 Dear Ms. McCarthy: on a no ca in see a canty, go catson whether retesting is required for one inner fiberboard box weighing 5 pounds if the packaging was combination packaging with tested with four 1 quart inner glass bottles weighing 2.5 pounds each. inner fiberboard box. You also ask whether there is a limit on the size of the Under $ 178.601 (g) (2), for combination packagings, Variation 2 allows inner packagings of any type in an outer packaging without retesting if the specific conditions of the variation are met. There is no restriction on the size of the inner fiberboard box, however, it may not exceed half of the gross mass (the weight of the inner packagings plus the weight of the contents) of the inner packagings used for the drop test. packagings must also comply with § 173.27 (c) (1) and (c) (2). For air transport, all of the provisions in S 178.601 (g) (2) (i) through (vii) If the combination packaging with one inner fiberboard box is not are met, need I hope this information is helpful. Please contact us if you further assistance. Sincerely, Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2JUL 16 2001 ! Ms. Linda McCarthy 2001 Mission Drive Defense Logistics Agency Ref. No. 00-0320 New Cumberland, PA 17070-5000 Dear Ms. McCarthy: This is in response to your letter and subsequent telephone conversation with a member of my staff requesting clarification of Variation 2 in 49 CFR 178.601 (g). Specifically, you ask whether retesting is required for a combination packaging with one inner fiberboard box weighing 5 pounds if the packaging was tested with four 1 quart inner glass bottles weighing 2.5 pounds inner fiberboard box. each. You also ask whether there is a limit on the size of the Under § 178.601(g) (2), for combination packagings, Variation 2 allows inner packagings of any type in retesting if the specific conditions of the variation are met. an outer packaging without There is no restriction on the size of the inner fiberboard box, however, it may not exceed half of the gross mass (the weight of the inner packagings plus the weight of the contents) of the inner packagings used for the drop test. For air transport, all of the provisions in $ 178.601(g) (2) (i) through (Vi1) are met, packagıngs must also comply with § 173.27 (c) (1) and (c) (2). the combination packaging with one inner fiberboard box is not required to be retested. need further assistance. I hope this information is helpful. Please contact us if you Sincerely, Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards DHM-12: McIntyre: 06/25/01 $ 178.601#

Page 311/16/2000 15:09 7177707143 DDC T PAÇE 01/01 DEFENSE LOGISTICS AGENCY DEFENSE DISTRIBUTION CENTER McIntyre 2001 MISSION DRIVE NEW CUMBERLAND, PA 17070-5000 8 118.60/19(z) IN REPLY REFER TO Packaging DDC-J3/J4-0 00-0320 MEMORANDUM FOR DOT, RSPA, OFFICE OF HAZARDOUS MATERIALS STANDARDS SUBJECT: Request For Interpretation of CFR49, 178.601 (g)(2) This office as the Defense Logistics Agency focal point for Performance Oriented Packaging (POP) testing receives questions concerning interpretations of the CFR 49 regulation. We have a question on the use of Selective Testing, 49 CFR, Paragraph 178.601 (g)(2) "Variation 2". Can a lesser number of larger packagings be shipped in a tested container meeting the requirements for testing of Variation 2 without further testing? For example, a packaging is tested with 4-1 quart inner glass bottles weighing 2.5 pounds each, total weight of inner packagings is 10 pounds, each 1-quart battle is eight inches in height and two inches in diameter. Provided the cushioning requirements can be satisfied, can one fiberboard box weighing 5 pounds, ten inches in height and four inches in diameter be substituted for the 1-quart original inner container? Is there an upper limit on the size of the fiberboard box? Thank you for your assistance in this matter. Action officer for this matter is Liada McCarthy, DSN: 977-8238, Commercial 717-770-8238, FAX extension is 7143. Spade ine Carthy Linda McCarthy Packaging Specialist Program Manager, POP .: Post-It® Fax Note 7671 pato /1/16/00 sages TE MAZZULLO ERE CARTHY COUP'ECTOR Boc Phone # Pha193-770-8238 F20 2-366-3012 1717-770-7143 i Federal Recycling Program Printed on Recycled Paper#