{"operation":"document","citation":"02-0240","title":"CARGOpak Corp. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-01-15","effective_on":null,"summary":"02-0240 response to CARGOpak Corp. concerning 178.60.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0240.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0240.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0240","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020240.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nResearch and\nJAN 15 2003\n400 Seventh St., S.W.\nWashington, D.C. 20590\nSpeciai Programs\nAdministration\nPresident\nMr. Robert M. Smith\nReference No.: 02-0240\nCARGOpak Corp.\n3215-A Wellington Court\nRaleigh, NC 27615\nDear Mr. Smith:\nThis responds to your letter requesting clarification of certain non-bulk packaging and testing\nrequirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You\ndescribe the following scenario: a shipper wants to offer Isopropyl alcohol, 3, UN1219, PG II, in\na non-bulk combination packaging for transportation by all modes. As an inner packaging, the\nshipper wants to use a one-gallon plastic bottle that meets the minimum 95 kPa test pressure\nrequirements in § 173.27(c)(2)(i) for air transport but has not been tested as part of the\ncombination packaging. Your questions are paraphrased and answered below:\nQ1. The shipper wants to purchase a fiberboard box marked UN 4G/Y9/S/02/USA/+AC1616 that\nand UN standards?\napparently has been tested with a similar plastic inner package. Is this in conformance with DOT\nAl. Variation 1 in § 178.601(g) permits certain variations in inner packagings of a tested\nperformance is maintained. See § 178.601(g)(1)(i)(A)-(F) for the specific changes that are\ncombination package without further testing of the package, provided an equivalent level of\nauthorized. It would be the responsibility, of the person making the changes, in this case the\nshipper, to ensure that the inner packaging provides an equivalent level of performance in all\nregards, such as compatibility, impact resistance, stack strength, etc. For air transport, the\npackagings must meet the applicable requirements in § 173.27.\nall nor one alon trial air packagickaging, does the as pandar sandin ackaging\nwithout retesting the entire packaging?\nanswer to Q1.\nA2. The term \"industry standard\" has no relevance within the context of UN standards. See\nQ3. Is a packaging that consists of a plastic bottle inner packaging, a plastic poly liner and a\nfiberboard outer packaging, tested and marked as in Question 1, acceptable for all modes of\ntransportation including passenger and cargo aircraft?\n178.60\n020240\n390e2:2373\n\n<<<PAGE 2>>>\n\nA3. The answer is yes, provided the completed package is an authorized packaging for the\nrequirements for both the standard to which it is marked and for air transportation. See answer to\nmaterial to be packaged, meets quantity limits for transport by aircraft, and meets all applicable\nQ1.\nI trust this satisfies your inquiry.\nMother mittele\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n09/06/02 FRI. 10:26 FAX 9198789244\nCargoPak Corp\n41002\nCorbin\n$178.601g.\nCARGOpak Corp.\nlestina\n9/6/2002\n02-02.40\nResearch and Special Programs Administration,\nU.S. Department of Transportation,\n400 Seventh St, S. W.,\nOffice of Hazardous Materials Standards,\nAttn: Mr. Ed Mazzullo\nWashington, DC 20590\nDear Mr. Mazzillo,\nCould you please clarify the following?\npassenger and cargo aircraft) Isopropyl alcohol, Flammable liquid Class 3; UN1219, PGII.\nA shipper wants to ship in non-bulk, combination packaging by all modes of transport (including\nminimum 95 kPa. test pressure requirement for air, but does not have a completely tested and\nAs an inner packaging she wants to use her own 1 gallon plastic bottle which meets the\ncertified UN specification package.\n1) Can this shipper purchase from a packaging supplier just the outer box component marked\nsimilar, but not the same, plastic inner package and be in compliance with the DOT/UN\nwith UN certification 4G/Y9/S/02/USA/+AC1616 which apparently has been tested with a\nstandards?\n2) Concerning the 1 Gallon, IP2 plastic inner package, does the term \"industry standard\" deem\nall similar but not identical inner packagings (e.g. different bottle manufacturer) be acceptable to\nmarkings without re-testing the entire packaging?\nuse with outer boxes that were tested with similar inner packaging bearing UN certification\nliner and a fiberboard box outer packaging without sufficient absorbent to absorb the entire\n3) Would a complete packaging consisting of the plastic bottle inner packaging, a plastic poly\nnodes of transport including passenger and cargo aircraft?\niquid content of the package, with the same certification markings as in 1) be acceptable for al\nThank you,\nsincerely\nRobert M. Smith\nPresident\n3215-A Wellington Court, Raleigh, NC 27615 USA •Tel: (919) 878-9933 - Fax: (919)878-9244 •http://www.cargopak.com","truncated":false,"body_characters":4574}