CARGOpak Corp. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Research and JAN 15 2003 400 Seventh St., S.W. Washington, D.C. 20590 Speciai Programs Administration President Mr. Robert M. Smith Reference No.: 02-0240 CARGOpak Corp. 3215-A Wellington Court Raleigh, NC 27615 Dear Mr. Smith: This responds to your letter requesting clarification of certain non-bulk packaging and testing requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You describe the following scenario: a shipper wants to offer Isopropyl alcohol, 3, UN1219, PG II, in a non-bulk combination packaging for transportation by all modes. As an inner packaging, the shipper wants to use a one-gallon plastic bottle that meets the minimum 95 kPa test pressure requirements in § 173.27(c)(2)(i) for air transport but has not been tested as part of the combination packaging. Your questions are paraphrased and answered below: Q1. The shipper wants to purchase a fiberboard box marked UN 4G/Y9/S/02/USA/+AC1616 that and UN standards? apparently has been tested with a similar plastic inner package. Is this in conformance with DOT Al. Variation 1 in § 178.601(g) permits certain variations in inner packagings of a tested performance is maintained. See § 178.601(g)(1)(i)(A)-(F) for the specific changes that are combination package without further testing of the package, provided an equivalent level of authorized. It would be the responsibility, of the person making the changes, in this case the shipper, to ensure that the inner packaging provides an equivalent level of performance in all regards, such as compatibility, impact resistance, stack strength, etc. For air transport, the packagings must meet the applicable requirements in § 173.27. all nor one alon trial air packagickaging, does the as pandar sandin ackaging without retesting the entire packaging? answer to Q1. A2. The term "industry standard" has no relevance within the context of UN standards. See Q3. Is a packaging that consists of a plastic bottle inner packaging, a plastic poly liner and a fiberboard outer packaging, tested and marked as in Question 1, acceptable for all modes of transportation including passenger and cargo aircraft? 178.60 020240 390e2:2373#

Page 2A3. The answer is yes, provided the completed package is an authorized packaging for the requirements for both the standard to which it is marked and for air transportation. See answer to material to be packaged, meets quantity limits for transport by aircraft, and meets all applicable Q1. I trust this satisfies your inquiry. Mother mittele Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 309/06/02 FRI. 10:26 FAX 9198789244 CargoPak Corp 41002 Corbin $178.601g. CARGOpak Corp. lestina 9/6/2002 02-02.40 Research and Special Programs Administration, U.S. Department of Transportation, 400 Seventh St, S. W., Office of Hazardous Materials Standards, Attn: Mr. Ed Mazzullo Washington, DC 20590 Dear Mr. Mazzillo, Could you please clarify the following? passenger and cargo aircraft) Isopropyl alcohol, Flammable liquid Class 3; UN1219, PGII. A shipper wants to ship in non-bulk, combination packaging by all modes of transport (including minimum 95 kPa. test pressure requirement for air, but does not have a completely tested and As an inner packaging she wants to use her own 1 gallon plastic bottle which meets the certified UN specification package. 1) Can this shipper purchase from a packaging supplier just the outer box component marked similar, but not the same, plastic inner package and be in compliance with the DOT/UN with UN certification 4G/Y9/S/02/USA/+AC1616 which apparently has been tested with a standards? 2) Concerning the 1 Gallon, IP2 plastic inner package, does the term "industry standard" deem all similar but not identical inner packagings (e.g. different bottle manufacturer) be acceptable to markings without re-testing the entire packaging? use with outer boxes that were tested with similar inner packaging bearing UN certification liner and a fiberboard box outer packaging without sufficient absorbent to absorb the entire 3) Would a complete packaging consisting of the plastic bottle inner packaging, a plastic poly nodes of transport including passenger and cargo aircraft? iquid content of the package, with the same certification markings as in 1) be acceptable for al Thank you, sincerely Robert M. Smith President 3215-A Wellington Court, Raleigh, NC 27615 USA •Tel: (919) 878-9933 - Fax: (919)878-9244 •http://www.cargopak.com#