{"operation":"document","citation":"05-0025","title":"C.L. Smith Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2005-07-27","effective_on":null,"summary":"05-0025 response to C.L. Smith Company concerning 178.601.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0025.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0025.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0025","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050025.pdf","body":"<<<PAGE 1>>>\n\nJ.S. Departmen\nof Transportatior\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nHazardous Materials Safety\nPipeline and\nAdministration\nJUL 27 2005\nMr. Lonnie Jaycox\nRef. No.: 05-0025\n1311 South 39'h Street\nC.L. Smith Company\nSt. Louis, MO 63110-2535\nDear Mr. Jaycox:\nThis is in response to your January 26, 2005 letter regarding testing requirements for\nspecification packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts\n171-180). Specifically, you ask if the addition of a liner bag and absorbent material in the\nvoid space of a previously tested combination packaging would require design qualification\ntesting as \"a different packaging.\"\nThe answer is no, provided the addition of the liner and absorbent material do not effect the\nstructural integrity of the combination packaging. \"A different packaging\" is defined in\n§ 178.601 (c)(4) as a packaging that differs from a previously produced packaging in\nTherefore, further design qualification testing is not required if the alterations to the\nstructural design, size, material of construction, wall thickness or manner of construction.\npackaging do not constitute \"a different packaging.\" In addition, the completed and filled\npackaging, after the liner and absorbent material are added, may not exceed the gross\nweight of the originally tested packaging.\nI hope this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\nTitle z. mitchell\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n178.601C)\n050025\n\n<<<PAGE 2>>>\n\nPage 1 of 1\nPollacbt\nINFOCNTR\n$178.601k)\nFrom:\nlonnie jaycox [ljaycox@clsmith.com]\nSent:\nWednesday, January 26, 2005 10:40 AM\n05-tun2s\nTo:\nINFOCNTR\nSubject: Absorbent fill\nnatural void space in the carton without the use of a fill or absorbent material (i.e. round bottles in\nIf a combination package has been tested and certified in a configuration that produces some\na square carton would have such voids even when the bottles are held securely in place in the\nwith air cells being used to position primary containers of any sort.), would the addition of a liner\ncarton, an inner container with a cone top produces the same effect, as would a nested partition\nthe package constitute a \"different package\" that would require re-testing; assuming of course,\nbag and loose fill material (such as a soft particulate absorbent) into the natural void spaces in\nthat the inner containers must be filled to a lighter weight than the originally tested design type in\ncomponents or assembly of the originally tested design type except to fill natural voids with a soft\norder to respect the gross package weight limitations and no changes are made to the\nCL Smith Co.\nLonnie Jaycox\nSt. Louis, MO 63110\n1311 South 39th Street\nljaycox@clsmith.com\n314-771-1202, ext: 267","truncated":false,"body_characters":2879}