{"operation":"document","citation":"04-0035","title":"Estes-Cox Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-04-05","effective_on":null,"summary":"04-0035 response to Estes-Cox Corporation concerning 178.516, 178.601.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0035.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0035.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0035","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040035.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAPR\n5 2004\nAdministration\nMs. Mary Roberts\nTechnical Services\nReference No.: 04-0035\nEstes-Cox Corporation\nP. O. Box 227\nPenrose, CO 81240-0227\nDear Miss Roberts:\nThis responds to your letter inquiring whether a very small fiberboard box can be tested and\ncertified as a UN standard packaging under the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). Estes-Cox Corporation manufactures Model rocket motors (NA 0323) and\nIgniters (UN 0454) which are shipped in performance oriented packagings to wholesalers and\ndistribution centers where they are repackaged for shipment in smaller quantities to retailers and\nindividuals throughout the United States. Your company wants to eliminate the need for\nrepackaging these items, and would like to test and certify a 3\" x 1-3/4\" × 7/8\" fiberboard box to\nthe UN 4G standard. You enclosed a fiberboard box with two empty model rocket motor casings\nto illustrate the size of the proposed box. Each UN 4G fiberboard box would be properly marked\nand labeled. Several UN 4G fiberboard boxes would be placed inside an overpack for\ntransportation.\nThe information provided to you by Ms. G. Corbin of this office that the fiberboard box\nspecifications in § 178.516 do not specify a minimum size, but prescribe a maximum net mass\nfor fiberboard boxes, was correct. Section 178.516 does not prescribe a minimum size for\nfiberboard boxes. Additionally, the UN Recommendations on the Transport of Dangerous\nGoods, Volume II, in 5.2.2.2 state: \"Labels shall be in the form of a square set at an angle of 45°\n(diamond-shaped) with minimum dimensions of 100 mm by 100 mm, except in the case of\npackages of such dimensions that they can only bear smaller labels.\" Section 172.401 (c) of the\nHMR permits use of those modified labels on small packages of hazardous materials.\nIn addition, when an overpack is used, it must be marked with the proper shipping name and\nidentification number, and labeled for each hazardous material it contains unless the markings\n§178.516\n$178.601\n040035\n\n<<<PAGE 2>>>\n\nand labels representative of each hazardous material in the overpack are visible. The overpack\nprescribed specifications when specification packagings are required.\nmust also be marked with a statement indicating that inside (inner) packages comply with\nI trust this satisfied your inquiry.\nSincerely,\nThothe z. Mishel\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n..........\n\n<<<PAGE 3>>>\n\nEstes-Cox\n1295 H Street\nwww.estesrockets.com\nCorporation\nwww.coxmodels.com\nO Box 227\nPhone: (719) 372-6565\nenrose, CO 81240-022:\nFax: (719) 372-3217\n3,147601\nFebruary 24, 2004\n§ 172406(6)\nOffice of HazMat Standards\nEdward Mazzullo, Director\nLabeling Packagings\nUS DOT/RSPA/DHM-10\n400 7* Street SW\n04-8035\nWashington, DC 20590\nRE: UN 4G Packaging\nDear Director Mazzullo:\nWe are a manufacturer of model rocket motors (NA 0323) and Igniters (UN 0454) and\nship these products in master pack quantities in performance tested fiberboard boxes (UN\n4G). We ship to wholesalers and distribution centers. They open the boxes and repack\nthe motors and igniters for shipment in smaller quantities to retailers and individuals\nshipments.\nthroughout the US. They also use performance tested fiberboard boxes (UN 4G) for their\nTo eliminate the need for our wholesalers and distributors to open and repackage these\nmodel rocket motors in UN 4G boxes. These small UN 4G boxes bearing the required\nitems, we are investigating the possibility of packaging quantities as small as one or two\nwould bear all of the required marking and labeling. The wholesalers and retailers would\nUN markings would then be packed inside overpacks in larger quantities. The overpacks\nthen need only to open the overpacks and to use new overpacks. They would not need to\nopen the individual UN 4G boxes:\ninches x I inch. This would be large enough for two of our model rocket engines and\nThe approximate size of one of the smaller boxes that we hope to use is 3 inches x 1¾\ntwo igniters. An example of the proposed box size with two empty model rocket motor\ncasings is enclosed. The example represents only the size of the box and not the final\nmaterial, style or construction.\nHowever, the box manufacturers and testers with whom we have been working have\nacceptable. I called the US DOT Information Hotline this morning and spoke to Gigi\nnever made or tested a UN 4G box this small and have concerns about whether it is\nabout this issue. Her quick research of the subject indicated that a box of that size\nappeared to be acceptable and she recommended that if we wanted something in writing\nthat we should write to you and request it. Therefore, we are writing to ask if you can\n\n<<<PAGE 4>>>\n\n'2\nprovide us with something in writing to share with our box manufacturers and testers to\nallay their concerns about the size of the proposed UN 4G box.\nThank you in advance. We eagerly await any information that may be provided.\nKind Regards,\n• Mary Koberts\nMary Roberts\nTechnical Services\nEnclosure:","truncated":false,"body_characters":5165}