TEN-E Packaging Services, Inc — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W. Washington, D.C. 20590 special Programs MAR 1 5 2002 Administration Mr. Robert J. Ten Eyck Technical Services Director Ref. No. 02-0026 TEN-E Packaging Services, 1666 Country Road 74 Inc. Newport, MN" 55055 Dear Mr. Ten Eyck: This responds to your letter dated December 20, 2001, regarding different packagings under the Hazardous Materials Regulations the addition of a leak-proof liner to a previously tested (HMR; 49 CFR Parts 171-180) . Specifically, you inquire whether as a different design type under S 178.601 (c) (4). fiberboard box design would require design qualification testing original tested design type (e.g., packaging assembly, closure Provided the liner does not compromise the integrity of the would not be considered a different packaging and, therefore, method), the addition of a liner similar form of containment would not require design qualification testing as type. a new design I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hate z. Mitche ? Hattie I. Mitchell Office Chief, Regulatory Review and Reinvention of Hazardous Materials Standards 178.601 (c)(4) 020026#

Page 201/18/02 12:02 FAX 6514591430 TEN-E PACKAGING 40001 Phone# Prom (251) 459-047 1(2023423012(651) 459-1430 TENCE Stevens 5178601(4 December 20, 2001 Packagings 02-0026 Office of Hazardous Materials, Standards DHM-10 Edward Mazzula Research And Special Programs Administration U.S. DEPARTMENT OF FRANSPORTATION Washington, DG 20590 400 Seventh Street, S.W. Dear Ed: plastic liner or plastic bag to a UN 4G box would constitute a different packaging under Section TEN-E Packaging Services is writing to request a clarification on whether or not the addition of a comply with new IATA requirements under Section 5.0.2.12 of their: Dangerous Goods 178.601(c)(4) of Title 49 CFR. TEN-E has recelved several calls from clients who are trying to Regulations, Effective January 1, 2002 dangerous goods sbippers must incorporate a leak-proof inner packagings that contain Class 3, 4, 8, 5.1 or 6.1 liquids, While we recogrize the fact that liner, plastic bag or other equally efficient means of cantainmehtfor combhation packagings with IATA does not carry the weight of law for international air shipments, it is a concern for shippers: because of its enforcement by carriers. constitutes a different packaging under Section 178.601(c)(4) of Title 49 CFR, but would like TEN-E does not feel that the addition of such a liner or bag to an'existing UN 4G container confirmation from. DOT so that we provide proper advice to our customers. Your Immediate attention to this matter is greatly appreciated. Sincerely Director, Technical Services RoberfleTon Eyok TER-1 Frowietng Services inc Ness. 4350) 55455 65t:452001) 651459.759 BA)#