Dangerous Goods — Hazardous Materials Safety Interpretation

Page 1Mr. Larry Snellings Reterence No.: 05-0285 Vice-President, Dangerous Goods P.O. Box 60543 AMF Houston, TX 77205-0543 Dear Mr. Snellings: This is in response to your October 27, 2005 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) to non-bulk performance-oriented packaging standards. Specifically, you ask for a definition of "other suitable means" used in the construction of natural wood and plywood boxes, respectively. The standards for boxes containing natural wood or plywood are found in §§ 178.513 and 178.514, respectively. The HMR do not specifically define "other suitable means." However, provided the strength of the material used is appropriate to the capacity and intended use of the box, the tops and bottoms of natural wood boxes may be made of materials similar to water-resistant reconstituted wood. Similarly, provided the strength of the materials used is appropriate to the capacity and intended use of the packaging, other materials may be used together with plywood in the construction of plywood boxes. I trust this satisfies your inquiry. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 178.513 178.514 050285#

Page 2DIRECTOR - OFFICE HM REGULATIONS 400 - 7T" STREET S.W. (DHM-10) Packagings WASHINGTON D.C. 20590 05 - 0285 REQUEST FOR LETTER OF INTERPERTATION: SIR, AFTER SPEAKING WITH YOUR FIELD AGENT, YOUR 800 HOTLINE AND YOUR OFFICE VIA PHONE I AM NOW FOLLOWING THE NEXT STEP IN THE PROCESS OF OBTAINING CLARIFICATION ON THE REGULATIONS, SPECIFICALLY CFR 49 178.513 FOR WOOD BOX / 178.514 FOR PLYWOOD BOX IN BOTH REFERENCES IT STATES THAT THE USE OF "OTHER SUITABLE MATERIAL" IS ALLOWED. IF POSSIBLE I NEED CLARIFICATION OF WHAT "OTHER SUITABLE MATERIAL" IS OR AT WHAT POINT OR PERCENTAGE OF MATERIAL USED IN CONSTRUCTION DOES A BOX MADE OF WOOD SIDES AND ENDS WITH A PLYWOOD TOP AND BOTTOM NO LONGER MEET THE REQUIREMENTS OF A "WOOD" BOX AND BECOME A PLYWOOD BOX. IN THE USE OF "OTHER SUITABLE MATERIAL" IS PLYWOOD CONSIDERED "OTHER SUITABLE MATERIAL" AND IF SO WHAT PERCENTAGE OF CONSTRUCTION CHANGES A BOX FROM BEING A WOOD BOX TO A PLYWOOD BOX. A COPY OF THIS REQUEST HAS ALSO BEEN SENT TO IATA AND THE UN REPRESENTATIVE FOR CLARIFICATION. YOUR ASSISTANCE IN THIS MATTER IS GREATLY APPRECIATED. RESPECTFULLY LARRY SNELLINGS VP DANGEROUSGOODS.COM HOUSTON TEXAS USA P.O. BOX 60543 AMF HOUSTON TEXAS 77205-0543 PH 281 821 0859 FX 281 821 6558 WWW.DANGEROUSGOODS.COM#