{"operation":"document","citation":"02-0124","title":"Inland Paperboard and Packaging, Inc — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-07-11","effective_on":null,"summary":"02-0124 response to Inland Paperboard and Packaging, Inc concerning 178.601.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0124.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0124.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0124","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020124.pdf","body":"<<<PAGE 1>>>\n\n-\nF..\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nJUL 1 1 2002\nAdministration\nMr. John H. Rutherford\nReference No.: 02-0124\nManager, Testing Solutions Lab\nInland Paperboard and Packaging, Inc.\n8501 Moller Road\nIndianapolis, IN 46268\nDear Mr. Rutherford:\nThis is in response to your letter requesting clarification of selective testing Variation 2 under the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180).\nYour customer has asked you to test and certify a combination package where the inner\npackagings are plastic bottles containing liquids as a Variation 2 packaging. Your customer has\ninterpreted § 178.601(g)(2)(i) to mean that glass is an example of a \"fragile inner packaging.\"\nYour questions are paraphrased and answered as follows:\nQ1. Is it permissible to use plastic inner receptacles conditioned to -18 °C (0 °F) in lieu of\nglass for the drop test required in § 178.601(g)(2)(i)?\nAl. The answer is yes. Drop testing of combination packagings with plastic inner packagings\nintended to contain liquids must be carried out when the temperature of the test sample\nand its contents has been reduced to - 18 °C (0 °F) (see § 178.603(c).\nQ2.\nCan we certify our combination packagings for Variation 2 using plastic inner\npackagings?\nA2.\nThe answer is yes, provided the specific conditions of the variation are met.\nQ3.\nAssuming we can test to Variation 2, should a statement be included in the certification\nreport that the packaging qualifies under § 178.601(g)(2) for selective testing of\ncombination packagings as long as no inner packagings more fragile than plastic at - 18\n°C (O °F) are used?\nA3.\nSuch a statement is permissible, but not required. Variation 2 allows inner packagings of\nany type in an outer packaging without retesting if the specific conditions of the variation\nare met.\n\n<<<PAGE 2>>>\n\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nHothes. Mitchet\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n:\n•\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nResearch and\nMAY 20 2003\nWashington, D.C. 20590\nSpecial Programs\nAdministration\nMr. John Rutherford\nManager, Testing Solutions Lab\nReference No.: 02-0124\nInland Paperboard and Packaging, Inc.\n8501 Moller Road\nIndianapolis, IN 46268\nDear Mr. Rutherford:\nThis letter replaces our July 11, 2002 response to your request for a clarification of selective\ntesting, Variation 2, under § 178.601(g)(2)(i) of the Hazardous Materials Regulations (HMR; 49\nCFR Parts 171-180). Variation 2 allows inner packagings of any type in an outer packaging\nwithout retesting if the specific conditions of the variation are met.\nYou stated that your customer asked you to test and certify a combination package where the\ninner packagings are plastic bottles containing liquids as a Variation 2 packaging. Variation 2\nstates that the outer packaging must be tested \"with fragile (e.g. glass) inner packagings\ncontaining liquids.\"\nOur responses to your paraphrased questions are as follows:\nQ1. Is it permissible to use plastic inner receptacles conditioned to -18 °C (0 °F) in lieu of\nglass for the drop test required in § 178.601(g)(2)(i)?\nA1.\nUnder the HMR, the drop test required in § 178.601(g)(2)(i) may be conducted using\ninner receptacles made of \"fragile\" plastic material. The intent of Variation 2 is to\nconduct the test with the most fragile inner packaging. Drop testing of combination\npackagings with plastic inner packagings intended to contain liquids must be carried out\nwhen the temperature of the test sample and its contents have been reduced to - 18 °C (0\n°F) (see § 178.603(c)). However, you should be aware that some Competent Authorities\ndeem only glass as fragile.\nA proposal, ISO 16104:2002(E), currently before the United Nation's Committee of\nExperts on the Transport of Dangerous Goods would require the inner packagings for \"v\"\nmarked packagings to be of glass, porcelain, or stoneware. If approved by the United\nNations, we may propose a revision to the requirements in § 178.601(g)(2)(i) of the HMR\nto make them consistent with the international regulations.\n\n<<<PAGE 4>>>\n\nQ2.\nCan we certify our combination packagings for Variation 2 using plastic inner\npackagings?\nA2.\nThe answer is yes, provided the specific conditions of the variation are met, including the\nuse of a plastic inner packaging that is considered to be \"fragile.\"\nQ3.\nAssuming we can test to Variation 2, should a statement be included in the certification\nreport that the packaging qualifies under § 178.601(g)(2) for selective testing of\n°C (0 °F) are used?\ncombination packagings as long as no inner packagings more fragile than plastic at -18\nSuch a statement is not required under the HMR, but we recommend that the Notification\nrequired by § 178.2(c) inform distributors and users of the type of inner packagings used\nin the certification test and advise that inner packagings that are more fragile may not be\nused.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nHottie z. Mithell\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 5>>>\n\n: Apr-22-03 10:15 packg Res 6104369422\nP.02\npackage is simply an extension of the origi-\nretaining its identity as one authorized and\nnal import movement, with the package\n§ 171.12(b) in conformance with IMDG\nCode requirements, or as a foreign-manu-\nLetter dated July 11, 2002 to\nused under the § 171.12(b) IMDG Code\nfactured package authorized for use within\nMr. John H. Rutherford,\nimport provisions. Thus, the packaging is.\nthe United States under § 173.24(d), the\nTesting Solutions Lab.\nnot being \"reused\" (i.e., used more than\npackage would be required to be reclosed in\nonce) - the return can be viewed a continu-\nsuch a manner as to conform to the manner\nI find DOT's responses in this letter quite\nport cycle for the package. So, in this regard\nation, indeed, the completion, of the trans-\nin which the packagings subjected to the UN\ncurious. Having worked very closely in\ndesign qualification tests were closed. It\n1990 at the United Nations Committee with\nthe DOT letter is quite correct - not with-\nremains unclear whether, or how, this infor-\nthe then-DOT International Standards\nstanding what might initially be viewed as a\nmation is to be provided to the customer\nCoordinator when what is now \"Variation\npossible inconsistency in terms of the con-\nclosing the package for return to Germany.\ni\n2\" in $ 178.601 (g) was first developed and\nditions imposed under § 171.12(b) (6).\nOne final comment. While the forgoing j tions, 1 recall rather cicarly that the intent of\nincorporated into the UN Recommenda-\nAt the same time, however, it is unclear\ndiscussion is offered in the context of the\nwhy DOT states that the requirement in\nIMDG Code \"import\" provisions appearing\nthese provisions was to use glass or some-\nthe packaging is subsequently returned to\n5s 173.24 and 173.24a would apply only if\nin § 171.12 (b), much of it would be equal-\n• thing of similar fragility for the design qual-\nly applicable to UN packagings transported\nification tests for \"V-marked\" packages. In\nwould appear to apply equally either to any\nthe United States - as these requirements\nunder the ICAO Technical Instructions pur-\nglass!\nfact, I would say not just glass, but fragile\n§ 171.11 differs from § 171.12(b) in that it\nsuant to § 171.11. Interestingly, however,\n§ 171.12(b), or to any foreign-manufac-\npackage exported under the provisions of\nmarked packaging was that it could be used\nThe fundamental underlying the V-\ndoes not impose as a condition that pack-\nunder the provisions of § 173.24(d).\ntured and marked UN packaging used\nages being exported must comply with the\ndesign qualification tests and packaging\nwith any inner packaging because the\napplicable requirements in §$ 173.24.\nand not addressed by DOT in its response,\nAn issue not raised by the questioner,\n173.24a and 173.28.\nquantity and thickness of absorbent mater-\nconfiguration (for example, in terms of\nis relevant to the scenario described. This\nSelective Testing of Variation 2\nial) demanded a very high level of perfor-\nconcerns the manner in which the package,\nmance. For example, as far as the tests\ntomer for return to Germany. Whether\nafter being emptied, is reclosed by the cus-\nPackaging\n• had to be used and with the drop always\nwere concerned, fragile inner packagings\nshipped for return under the provisions of\nReference $178.601,\nfrom the Packing Group I drop height and\nfound on page 53 of this issue.\n--\n• that which would be authorized for use in\nwith the mass of inner packagings twice\ngh Package and\nv-gh\nProduct Testing\nand Consulting, Inc.\n• Vibration\n= Impact shock\n• Compression\nISO 17025 accredited*\n• Material analysis/testing\nEngineers & Technicians have been IATA trained and tested\n• Environmental\nConditioning\nEvaluate and Certify Package\n• Video Conferencing,\nProduct Performance Services\nHigh Speed Video\nPendulum Impact Tester,\nI.S.T.A. (all projects), ASTM, NMFC, U.N./D.O.T Hazmat).\nProducts up to 8000 Ibs. tested\nGSA, Fed & Mil Spec Testing\nEASTERN FACILITY *\nWESTERN FACILITY\n(513) 870-0080\n(623) 869-8008\nFax: (513) 870-3017 Email: info@ghtesting.com\n325 Commercial Dr., Fairlield, OH 45014\n335 W. Melinda Lane, Phoenix, AZ 85027\nFax: (623) 869-8003 Email: info @ghtesting.com\nSeptember/October 2002\nCopyright 2002 Packaging Research International, Inc. • 877-429-7447 • Reproduction Prohibited\nHAZMAT Paciager & Shipper 19\n\n<<<PAGE 6>>>\n\nApr-22-03 10:15 packg. Res 6104369422\nP.03\nthe field. It would appear that use of plastic\nsequenty, packagings manufactured from\naging design qualification tests, and, con-\ninner packagings to qualify a V-marked\npackage could seriously undermine this\nthat fibreboard considered to be of a \"dif\nHAZMAT\nthe plastic inner packagings, used when\nunderlying philosophy - unless, of course,\nferent design type. DOT has typically held\nthat the fibreboard must be \"virtually iden-\nconditioned to -18°C, become more fragile\ntical\" - but what, exactly does that mean?\nPackager i Shipper\nthan glass!\nor another on that issue. In the first (to Mr.\nEach of these letters touches in one way\nMoreover, the statement - which DOT\nacknowledges is \"permissible,\nbut not\nDOT states that fibreboard with a basis\nSenzel) it is not in any way surprising that\nHAZMATIPS\nrequired\" - suggested for inclusion in the\npackaging test report that the packaging is\nweight different from that of the board used\nis \"more fragile than plastic at -18°C\" (what\nsuitable provided no inner packaging used\n1. What is the intent of \"Variation\nen machi ate packagings,\n2\" in 49 CFR 178.601(g)(2)?\nkind of plastic?) appears also to run\nis, the V-marked packaging is supposed to\ncounter to this underlying philosophy. That\ntype]\". In the second letter, in response to\nThis variation was agreed to by the UN\n\"each run of corrugated board may provide\nconcerns expressed by the writer that, since\nto permit, without a full requalification\nof inner packagings different from those\ndesign test, the conditional substitution\nbe authorized for any inner packaging -\nwith no \"strings\" attached.\ndifferent [cobb test] results\" a certification\nof discussions that took place at the UN\nIt is entirely possible that my recollection\nrequested by customers that all board pro-\ntested in the original design tests. This is\nduced can \"pass\" the Cobb test should be\nto be accomplished by drop testing a\nCommittee so many years ago is flawed.\nedges that no such \"blanket statement\" is\nviewed as \"unacceptable\", DOT acknowl-\na greater total combined package weight\ndecidedly most fragile inner packaging at\ndirect knowledge) that the view stated by\nNevertheless, I have some concer (but no\nrequired by the HMR. Curiously (and\nthan would be authorized for actual ship-\nother national \"competent authorities\" when\nDOT in this letter would not be shared by\ngo on to state that it is nevertheless a\nalmost humorously), however, DOT fails to\nment by the markings. The theory was\ninner packagings in a combined heavier\nthat by using a combination of fragile\ninterpreting the corresponding provisions in\nrequirement (blanket statement to cus-\nthe UN Recommendations, ICAO Technical\nboard used in the manufacture of UN certi-\ntomers or not) of the HMR that all fibre-\nunit in a successful drop test, it would be\nInstructions, ADR. etc. And even if simply\ntesting, for the modified combination\nsafe, without repeating complete design\nbased on the need to ensure a very high level\nfied 4G outer packagings be capable of\n\"passing\" that test!\npackaging to be used with any suitably\nof performance with V-marked package in\nin terms of fibreboard properties means at\nSo, it may be concluded that \"identical\"\nprotected inner packagings.\nactual transport - as opposed to strictly sat-\nisfying the minimum requirements of the\nencourage the design qualification testing of\nHMR - I would personally be reluctant to\nleast the same basis weight and capable of\n2. Can DOT authorize the use of\nlevel in the Cobb test. But it means even\nmeeting the same minimum performance\n\"non-glass\" inner packaging\na V-marked package with any inner packag-\nby using in the Variation 2\ning other than one of glass. And fragile glass\nmore, and it is important to take all relevant\ndrop test, an inner packaging\n(whatever that may be) at that!\nfactors into account in assessing whether\nthat might not be \"as fragile as\nis \"virtually identical\" to that used in the\nfiberboard used in production packagings\nfragile can be» and then quali-\nFiberboard Packaging Properties,\npackagings subjected to the design qualifi-\ntying its \"lesser fragility\"?\nDesign Qualification Testing\ncation tests. In this regard, DOT has previ-\nously stated in various interpretations that\nconcept is clear based on one of its \"clar-\nThat DOT appears to have adopted this\nReference $§ 178.601 and 178.516,\nfound on page 53 of this issue.\nfibreboards must have the same burst\nto be \"virtually identical\" to one another\nification letters. But the author points out\nLetters dated August 2, 2002 to\nthat some doubt may exist about this\nMr. Tony Senzel of Corrugated\nstrength, edge crush resistance, water\nabsorption rate, board weights, manner of\napproach in view of the history of this\nconstruction, flute and caliper. Moreover,\nexception and consequently its potential\nSupplies Corporation and to\nDOT has always prefaced such listings of\nunacceptability by other competent\nMir. Richard M. Thomas of\nproperties by the words \"such as\" - imply-\nauthorities. There might be a question\nSmurfit-Stone Container Corporation.\nwhether DOT has exceeded the authority\ning that other characteristics may be rele-\nvant to the determination of what is \"virtu-\nagreed upon by the international commu-\nnection with UN \"4G\" fibreboard combina-\nAn issue that frequently arises in con-\nally identical\" (but, unfortunately, never\nnity. The author believes that any person\nexplicitly stating what these additional\nvery cautiously. [Editor's NOTE: Fragile is\nusing such an approach should do so\ntion packagings, is what degree of variation\nated before the fibreboard is viewed as a\nin the properties of fibreboard can be toler-\ncharacteristics might be!). #\nmay feel that it has more precisely limited\nnot a defined term in the UN and DOT\n\"different\" material from that used in pack-\nwhat is being authorized.]\nmanh Intornalinnal inc. • 877-429-7447 • Reproduction Prohibited\nSeriestes/Octrier 2042\n\n<<<PAGE 7>>>\n\nApr-22-03 10:16 packg Res 6104369422\nP.04\nUS DOT\nInterpretations\n§ 178.516 August 2, 2002\nI hope this answers your inquiry.\naging qualifies under $ 178.601 (g) (2)\nThis responds to your January 29, 2002\nletter requesting clarification on package\nSincerely,\npackagings as long as no inner pack-\nfor selective testing of combination\ntesting under the Hazardous Materials\nDelmer F. Billings\nagings more fragile than plastic at -18\nRegulations (HMR; 49 CFR Parts 171-\nChief, Standards Development\noC (000) are used?\n180). Specifically, you ask if your box\noffice of Hazardous Materials Standards\nplant can be required to sign a blanket\nA3. Such a statement is permissible, but\nstatement guaranteeing that fiberboard\nnot required. Variation 2 allows\n\"pass\" the 30-minute Cobb Water\nused in the outer packaging will always\n§ 178.601 July 11, 2002\ninner packagings of any type in an\nouter packaging without retesting if\nAbsorbency Test. You also ask what\nmust pass the Cobb Test, the \"combined\"\ning clarification of selective testing\nThis is in response to your letter request-\ntion are met.\nthe specific conditions of the varia-\n(corrugated fiberboard material) or the\nMaterials Regulations (HMR; 49 CFR\nVariation 2 under the Hazardous\nonly), and, what results to use, an indi-\n\"base material\" (outer liner component\nI hope this information is helpful. If you\nParts 171-180).\nhave further questions, please do not\nindicated in the ISO International\nvidual result or average of test results as\nhesitate to contact this office.\nStandard 535 provisions?\nYour customer has asked you to test and\ninner packagings are plastic bottles con-\ncertity a combination package where the\nSincerely,\nAccording to your letter, 3rd party\ntaining liquids as a Variation 2 packag-\nHattie L. Mitchell\nand/or self-certified labs are requesting\nthat your box plants sign blanket state-\ning. Your customer has interpreted\nChief, Regulatory Review and Reinvention\nis used in their outer packaging always\nments guaranteeing the fiberboard that\nan example of a \"fragile inner packag-\n§ 178.601 (g) (2)(i to mean that glass is\nOffice of Hazardous Materials Standards\ning.\"\nbelieve that this type of practice is unac-\n\"pass\" the 30-minute Cobb Test. You\n§ 178.602 July 17, 2002\nceptable since each run of corrugated\nYour questions are paraphrased and\nanswered as follows:\nThis responds to your April 25, 2002 let-\nboard may provide different results. The\nter requesting we consider alternative\nHMR do not require blanket statements\n21. Is it permissible to use plastic inner\ntesting procedures to those under the\nalways pass the Cobb Test. Decisions\nguaranteeing that the fiberboard will\nreceptacles conditioned to -18°C\n49 CFR Parts 171-180). Specifically, you\nHazardous Materials Regulations (HMR;\nregarding such business\n(0°F) in lieu of glass for the drop\nshould be negotiated between your com-\npractices\ntest required in § 178.601 (g) (2) (i)?\nyou are recommending for retesting of\nask that we consider two options that\npany and your customers.\nA1. The answer is yes. Drop testing of\npreviously certified UN hazardous mate-\ninner packagings intended to con-\ncombination packagings with plastic\nrial packages. You state that these rec-\nIn your package testing scenario, the\nommended testing procedures will help\nCobb Test is conducted on the \"com-\nwhen the temperature of the test\ntain liquids must be carried out\nthe environment and reduce waste and\nbined\" (corrugated fiberboard material)\ncosts involved with UN hazardous mate-\nand it fails to pass the Cobb Test. If the\nsample and its contents has been\nrials testing. You further state that these\nCobb Test was then conducted on the\nreduced to -18°C (0°F)\n§ 178.603 (c).\n(see\nonly when agreed upon by the custome\necommended options are to be use\nponent only) that was actually used in\nactual \"base materials\" (outer liner com-\nand testing laboratory performing the\nthe box and the base material passes,\n22. Can we certify our combination\ntest.\nuse. Section 178.516 (b) (1) requires the\nyou ask which set of results should you\npackagings for Variation 2 using\nplastic inner packagings?\nYou propose the following options:\nouter surface of the combined board to\nrequired for drop tests be reduced to\nOption #1 - The quantity of packs\nbe tested, not the \"base materials\" or\nouter liner component. ISO International\nA2. The answer is yes, provided the spe-\nmet.\ncific conditions of the variation are\nthree (3) packs with multiple drops per-\nage, therefore, the average test results\nStandard 535 specifies using the aver-\nrmed on two (2) packs, and Option :\nUse only two (2) complete filled pack\ndetermine whether the fiberboard passes\n23. Assuming we can test to Variation 2,\nrecommend these procedures for: (1)\nfor stack, vibration and drop testing. You\nor fails the Cobb Test.\nshould a statement be included in\nthe certification report that the pack-\nretest only when no substantial change\nin supplier or material has been made\nSeptember/October 2002\nCopyright 2002 Packaging Research Intemational, Inc. • 877-429-7447 • Reproduction Prohibited\nMAZHAT Pachaper & Stiper 53\n\n<<<PAGE 8>>>\n\nApr-22-03 10:17\npackg Res 6104369422\nP.05\nQuestions\n« Answers I\nthereby allowing difterent, less\nunder actual transport, etc.) -\nfragile inner packagings of lesser\nNO&A\nfilled weight to be substituted for\ndesign qualification tests.\nthe inner packaging(s) used in the\nMAT\nHaving said this, however, there\nare still a number of conditions\nuse of V-marked packagings that\nand limitations that apply to the\nBy Andy Altemos, Technical Advisor\nmust be borne in mind when pack-\nO: Could you clarify what require-\nments must be met relative\non the \"Selective testing of combina-\nin § 178.601 (g) (2) as \"Variation 2\"\ning inner packagings in V-marked\npackages in order to ensure the\nfor hazardous materials? My\nto using V-marked packagings\ntion packagings\". Packagings con-\nthe regulations. As with any UN\npackage is used in compliance with\nunderstanding is that the per-\nforming to this selective testing\nformance capabilities of this\nvariation\" are frequently referred\ned packaging, it is imperative to\nSpecification, performance-orient-\ntunity to package a wide range\nproduct may present the oppor-\nto as\nbecause §§ 178.503(a) (2)\n\"V-marked\" packagings\nand\nor limitations arising from the\nadhere to any relevant conditions\nof hazardous materials by the\nings conforming to the variation to be\n178.601 (g) (2) (vii) require packag-\nconfigured for testing. These are\nmanner in which the package was\noverestimated how these pack-\nvarious modes. Have shipper's\nthe applicable UN packaging code\nmarked with the letter \"V\" following\ncertification for the packaging,\nas identified in the test report or\nprecautions must I take with\nagings can be used, and what\n(for example, \"4GV\" or \"LAZV\" for\nthem? Can they be reused?\nconforming combination packagings\nsure\" instructions (required under\nand/or the manufacturer's \"clo-\nwith a fiberboard box or removable\nA: Certainly, the \"V-marked\" packag-\nrespectively).\nhead steel drum outer packaging,\n§ 178.2(c) of the HMR to be pro-\nvided by the manufacturer to each\ning is a packaging designed and\ntransferred). In addition, in the\nperson to whom the packaging is\ncompliance with the packaging\nintended to be used to achieve\nAs stated in the introductory sen-\nrequirements for many different\nunderiying purpose of the varia-\ntence to § 178.601(g) (2), the\napplicable conditions and limita-\ncase of V-marked packagings, any\npackagings and under a wide\nmaterials in a variety of inner\ntion is to allow articles or inner\narray of circumstances. At the\nassembled as a combination pack-\npackagings of any type to be\nTachnical Actviser to\n¡ Andy Altemos is:\"\nsame time, it is my experience that\n\"overestimation\" of the ability of\nin many cases there has been an\naging and transported without\nHAZMAT Packager &\nfiguration of inner packaging and\nneed for testing that specific con-\nSnipper, and is a partner\nin the firm, HMT S\nsuch packagings to be used in a\npackaging components). This\nouter packaging (including related\nAssociates, L.C.C,\ncompliant manner owing to a mis-\nand limitations that attach to the\nunderstanding of the conditions\nallows a variety of inner packag-\n. Alexandria, VA. Mr.\nings that have not been tested in\nAttemos was formerty Secretarial to the\nuse of such packagings.\n\"design type\" to be assembled and\nthe outer packaging as a defined\nInternational Civil Aviation Organization's\nassignment he was international Standards\n(CAO) Dangerous Goods Pandl, Prior to that\nWhile this discussion of \"V-marked\"\noffered for transport in compliance\npackagings will focus on the applica-\nsafety in the transport of these\nwith the regulations. To ensure\nCoordinator in the U.S. DOT Research & :\nble requirements in the DOT\nSpecial Programs Administration, in which\nHazardous Materials Regulations\n(\"HMR\"), readers are advised that\nnation packagings, the underlying\nuntested configurations of combi-\nexpert capacity he represented the United\nin the UN Model Regulation and in\nessentially the same provisions exist\naging is to perform the design\nphilosophy of the V-marked pack-\nStates at the meetings of the United Nations\n(UN) Committee of Experts on the Transport\nthat standard - for example, the\ninternational regulations based on\nwith \"fragile\" inner packaging(s)\nqualification tests on the package\nof Dangerous Goods and its subsidiary bod-\nies, the International Maritime Organization's\nIMDG Code and the ICAO Technical\nunder exceedingly conservative\nSub-Committee on the Carriage of Dangerous\nInstructions (and the associated IATA\nconditions (e.g., from the Packing\nGoods and served as the United States' mem-\nthe HMR, the basic requirements for\nDangerous Goods Regulations). In\nGroup I drop height, with the inner\nber on the ICAO Dangerous Goods Panel.\nthe \"V-marked\" packaging are found\ngross mass that will be allowed\npackagings filled to twice the\nHe may be contacted by telephone at 1 (703)\n549-0727, or fax at 1 (703) 549-0728.\n12 HAZMAT Paskaper 8 Shier\nCopyright 2002 Packaging Research International, Inc. • 877-429-7447 • Reproduction Prohibited\nMarch/April 2042\n\n<<<PAGE 9>>>\n\nApr-22-03 10:18 packg Res 6104369422\nP.06\n* Questions\n& Answers •\ntions imposed by § 178.601 (g) (2)\nmust also be satisfied. Some\nexamples of considerations in the\nuse of V-marked packagings aris-\nitations are outlined below.\ning from these conditions and lim-\nSelective Testing of Combination Packagings.\n• Variation 2. Section 178.601(g)(2)\nthe use of V-marked packagings is\nOne area commonly overlooked in\n:; assembled and transported without testing in an outer packaging urider the\n: Articles or inner packagings of any type, for solids or liquids, maybe\nthickness of cushioning material\nthe requirement governing the\nfollowing conditions:\nbetween inner packagings and\nouter packagings (see § 178.601\nbetween inner packagings and\n*(i) The oüter packaging \"must have been successfully tested in accordance\nregulations require the cushioning\n(g) (2) (ili) on page 13). Here, the\nat the Packing Group i drop helght;\n. with 178.603 with fraölle (e.g. glass) inner packagings containing liqulds\nthan that used in the design quali-\nmaterial thickness to be not less\none half, the gross mass ofinger packagings used for the drop test,\n::) the total combined, gross mass of inner packagings may not exceed\nfication test. So, it is necessary for\ntest report and/or manufacturers\nthe user to consuit the packaging\nle thickness of\nsushering materal between inter backaginds and\ninstructions to determine the mini-\nniner packagings and the outside of the packagingmay.motspe\nensure that this minimum thick-\nmum thickness required, and to\na sinale inner\nnong thickness in the originally tested packaging;\nShioning betwee\nackaging was used in the original test the thick-\nalways maintained between inner\nness of cushioning material is\nushioning between\nInner packagings máy not be less thạn th thick-\npackagings and between\npackagings and the outer packag-\ninner\nng:\nthe original test\nne outside of the packaging and the inner pack\ncompared to the\nhen either fewer or smaller ner packagings are\nin the design qualification test but\na single inner packaging was used\noffered for transport. In addition, it\ning in each V-marked package\nadditio\nal cushioning mater al must be used to take up, void spaces se\nnner, packagings used in the drop test), suicient\n(v) the outer packaging must have successtuly passed the stacking\nforth n $178.606 of this subpart when empty, i.e; withoat ether inher back-\nFast set\nthe V-marked packaging is to be\ninner packaging, the thickness of\nused to transport more than one\ngings\nCushioning materials. The total mass of identical packagest\nthe combined m\nlasstof inner packagings used for the drop te\nast be\npackagings must always be at least\ncushioning material between inner\npackagings\n• CO\ntaba lauds must he completory.\nthat existing between the inner\nIcient quantity.\nabsörbent materials to absorb the. entire guid\nSurrou\nthe design qualification test.\npackaging and outer packaging in\nthe inner packagi\nthe outer padean intended to coman hel\nThe V-marked packaging require-.\nof few or smaller inner packagings\nments specifically address the use\nAs not leakproo or s intended to contain miner\nKadi\nIS not: sittproo\n- in which case sufficient addition-\nthan used in the tested design type\nevent of lea\nmeans of containing anya quid\nfor.\nbag, or other equaly efficient means of\ngi must be provider n mee\nal cushioning material must always\nbe used to take up all void spaces.\naining quasa the absorbent matenal\n(this section must be placed inside the means of containing\nrequired in pa\nThe regulations clearly imply that\nused than were used in the design\nmore inner packagings may be\nnts; and\nqualification test (see discussion in\nings must bermarked in acco\nseen tested to Packing Group I Partormance for combination\nroance\n78.603 or his.pa\nregarding\n§ 178.601 (g) (2) (ili) and above\nthickness between inner packag-\nrequired cushioning\nThe marked\naximum gross mass, may not exceed the\ning was used in the design qualifi-\nings when only one inner packag-\ngings of the tested combination packaging An additio\n(the outer packaging plus one half the mass, of the tilled\nble requirements are met.\ncation tests) - provided the applica-\ny$178.603(a)(2) of this part must include the letter?\ninemarking\nMarch/April 2002\nCopyright 2002 Packaging Research International, Inc. • 877-429-7447 • Reproduction Prohibited\nHAZMAN Packager & Stiper 13\n\n<<<PAGE 10>>>\n\nApr-22-03 10:21\npackg Res 6104369422\nP.O7\nQuestions\n& Answers\ninner packagings than were used in\nBut what about using fewer langer\nple, inner packaging and net pack-\nthe design qualification tests? The\nage quantity limits, and the capabil-\napplicable requirements, condi-\nregulations are silent on this, but a\nity of inner packagings containing\nin the regulations and by the\ntions and limitations as prescribed\nDOT interpretation letter written in\nliquids to withstand the prescribed\nJuly 2001 suggests that this is per-\npressure differential without leak-\ntake appropriate steps to ensure\npackaging manufacturer, and to\nmissible provided the weight of the\nemployees utilizing these packag-\nlarger inner packaging(s) does not\nauthorized use. *\nings are properly trained in their\nexceed one-half the aggregate gross\nin the design qualification tests (as\nweight of the inner packagings used\nprovided in 5 178.601 (g) (2) (i).\nis silent on the question of the thick-\nUnfortunately, the DOT interpretation\nHAZMAT\nin such a case. It may be assumed\nness of required cushioning material\nFinally, with regard to reuse of V-\nmaterial between the larger inner\nthat the thickness of cushioning\nPackager - Shipper\npackagings and between the larger\ninner packaging(s) and the outer\nspecifically prohibited from reuse\npaper, plastic film or textile being\nHazmat Tips\nthat existing between the inner pack-\npackaging must always be at least\nby § 173.28 (b) (3) of the HMR\nagings and between the inner pack-\n(\"liberboard\" not being consid-\nUse of V-marked\nagings and outer packaging in the\nposes of\nered by DOT as \"paper\" for pur-\ndesign qualification test. However, it\nthis\nHowever, for practical reasons the\nprohibition).\nPackagings\nwould ensure sufficient protection for\nmay be questioned whether this\npossibility of reusing fibreboard\nWhat is a V-marked packaging?\na larger, heavier inner packaging.\nregulations is highly problematic.\npackagings in compliance with the\nThis is a special type of UN specifica-\nWhen V-marked packagings are\nbulk packagings in S$ 173.28(a)\nThe reuse requirements for non-\nto be used to meet packaging require-\ntion packaging designed and intended\nused for the transport of liquids,\ninner packagings must be sur-\nand (b) would apply. Thus, any\na variety of inner packagings under a\nments for many different materials in\nrounded with a sufficient quantity\npackaging showing evidence of\nof absorbent material to absorb the\nreduction in integrity (including\nfor a variety of inner packagings that\nwide array of circumstances. It allows\nentire liquid contents of the inner\npunctures, tears, de-lamination,\npackagings. This includes when\netc., in sides or flaps) may not be\nhave not been tested in the outer\n\"larger\" inner packagings are used,\nreused. Closure of the reused\nnevertheless to be assembled and\npackaging as a defined \"design type\"\nas discussed above.\naccordance with the manufactur-\npackaging would have to be in\noffered for transport.\nAnd, of course, as is the case with\ntionable whether, for example,\ner's instructions - and it is ques-\npackaging, the manner of closing\nany UN Specification combination\nWhich previous means of closure\nretaping or resealing flaps from\nWhere do 1 find the requirements for\nV-marked packaging?\nthe packaging must conform to the\nmanufacturer's closure instructions\nhad been removed for even not\nSee § 178.601 (g)(2) in the DOT\n- for example, in the case of a fibre-\nremoved) would comply with the\nHazmat regulations, noted as\nboard box combination packaging,\nclosure method specified by the\n\"Variation 2\"(see page 13).\nbox flaps must be closed and the\nmanufacturer for a \"new\" packag-\nbox sealed with the same type of\ning of the same design type.\nspecial markings and where do I find\nDo V-marked packagings require\nfied by the packaging manufactur-\ntape or method of closure as speci-\nSo, while the V-marked packaging\nthese rules for how to mark them?\ner. Moreover, the gross weight of a\nis an extremely valuable tool to\nfilled packaging may never exceed\nensure compliance in the packag-\n(2) (vii) of the DOT regulations.\nSee §§ 178.503(a)(2) and 178.601 (g)\nthe gross mass indicated in the UN\nmaterials in many different inner\ning of a wide variety hazardous\napplied to the package.\npackaging certification markings\nconditions and limitations associ-\npackagings, there nevertheless are\nGo to Andy Altemos presentation in\nIf the V-marked package is to be\nings that must be observed\nated with the use of these packag\nyou clarify what requirements must be\nHAZMAT Q&A, page 12, titled, \"Could\nrequirements for air transport must\ntransported by air, all the general\nings in their transport operations\nReaders employing these packag-\nings for hazardous materials?\" for an in\nmet relative to using V-marked packag-\nbe satisfied - including, for exam-\n14 HAZMAT Packager & Shines\nale encouraged to review the\ndepth look at V-marked packaging.\nCopyright 2002 Packaging Research International, Inc. • 877-429-7447 • Reproduction Prohibited\nWarch/April 2002\n\n<<<PAGE 11>>>\n\nLetter To: Mr.-\nJohn\n7/1/0z\nRuther ford\n02-0124\nCorbin, Gigi (DHM12)\nSent:\nFrom:\nBurger, Donald\nTo:\nWednesday, November 13, 2002 10:45 AM\nSubject:\nCc:\nMazzullo, Ed; Wybenga, Frits; Hochman, Charles; Mitchell, Hattie\nCorbin, Gigi (DHM12)\nRE: Interpretation relative to the V marked package\nThe as we discussed the only issue with the letter that I see is that we failed to mention that \"the plastic inner packages\nvith that section, the person or laboratory performing the test would already know that the inners need to be \"fragile\" an\need to be 'fragile' in accordance with 178.601(g)(2).\" But with that said, if the package were to be certified in accordanc\nthe need to restate that requirement is redundant.\nIf using the \"most fragile\" inner package was the intent of the variation, it is not conveyed by the way the variation is\nwritten, it only requires the inner package to be \"fragile\" not the \"most fragile\".\nAdditionally, it is impossible to make a blanket statement about the fragility of one material in comparison to another. We\ndesign of the package. Thus we rely on the vague term fragile to define when this variation can be used. Fragile is\ncan not say that glass is always more fragile that plastic or vice versa; it is all related to the type of glass or plastic and the\ndefined as likely to break if not protected.\nin each of the other variations bit absent from variation 2. We can only infer that an equivalent level of safety is maintained\nFinally, the intro to 178.601(g)(2) makes no mention of maintaining an equivalent level of safety; it is specifically addressed\nthrough the testing of the \"fragile\" packages and replacing them with other inner packages.\nDon B\nFrom:\n-Original Message.\nSent:\nTo:\nWednesday, November 13, 2002 10:28 AM\nCorbin, Gigi (DHM12)\nSubject:\nBurger, Donald\nFW: Interpretation relative to the V marked package\nWould you care to comment on Frits' e-mail. The UN Recommendations do not refer to the \"most fragile\" and they do\nnot have the statement about an \"equivalent level of packaging.\"\nGigi\nThanks.\nFrom:\n-- Original Message....\nSent:\nMitchell, Hattie\nTo:\nCorbin, Gigi (DHM12)\nWednesday, October 30, 2002 9:21 AM\nSubject:\nFW: Interpretation relative to the V marked package\nPlease resolve. Thanks.\nFrom:\n-Original Message---\nSent:\nWybenga, Frits\nTo: Mazzullo, Ed; Mitchell, Hattie\nWednesday, October 30, 2002 8:28 AM\nSubject:\nCc: Burger, Donald; Hochman, Charles; Richard, Bob; Pfund, Duane\nInterpretation relative to the V marked package\nEd, Hattie - there is an interpretation to the V marked packaging requirement that was written up in the latest Hazmat\nof sing with the way other competent authorities would view the question.\npackager and shipper. I tend to agree with Andy's evaluation that we missed the mark on this and are somewhat out\n1\n\n<<<PAGE 12>>>\n\nThe intent of the V marked packaging requirements was to take the most fragile inner packaging one could imagine\nand put it in the package and subject it to testing more severe than normally required. The thought was by qualifying\nthe package with the most fragile inners anticipated the package it would then be suitable for all inner packagings.\nThis thought is lost in the interpretation provided on 1786.601, July 11, 2002. We allow a plastic package but fail to\nmention that the tested inner must be fragile - the response does not cover the fragility of the plastic inner relative to\nmaintained - we don't mention this either. I haven't read the requirement on manufacturers having to report shortages\nother inners that may be used. The intro to all the variations emphasizes that an equivalent level of safety must be\nto package fillers recently but would it be unreasonable to put some notation in there what the limitations on the use of\nthe V marked packaging are?\nPlease take another look at this interp - thanks.\nDeputy Associate Administrator for Hazardous Materials Safety\nFrits Wybenga\nResearch and Special Programs Administration\nU.S. Department of Transportation\n400 7th Street, S.W., Room 8321\nWashington, D.C. 20590-0001\nTel.: (202) 366-0656\nE-mail: frits.wybenga@rspa.dot.gov\nFax: (202) 366-5713\nWebsite: http://hazmat.dot.gov/\n2\n\n<<<PAGE 13>>>\n\nTSA\nIndianapolis\n3173906921\n03/17103 03: 33P P.001\nIndianapolis Field Office\nOffice of Security and Investigations\nIndianapolis, Indiana 46241\n5420 West Southern Avenue, Suite 203\nFederal Aviation Administration\nDepartment of Transportation\nOffice: 317-390-6900\nFax: 317-390-6921\nFAX\nDate: 3/17/03\n_Time: 1520\nNumber of pages to follow:\nRecipient: Hattie mitchell\nSender: Reginald McDaniel\nAgency:RSPA\nFax No:\nAgency: FAA\nTitle:\nSpecial Agent\nMessage\n•\nConfidentiality Notice\nThe documents accompanying this facsimile transmission may contain confidential information, which is legally\nfacsimile in error, pl","truncated":true,"body_characters":145972}