Guidanceguidance
07-0009
gh Package & Product Testing and Consulting, Inc. — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1s. Depanmel Transportatic Washington, D.C. 20590 400 Seventh Street, S.W. ipeline and Hazardou laterials Safety Administratio MAR Mr. H. Perry Hock Technical Director Ref. No.: 07-0009 gh Package & Product Testing and Consulting, Inc. 4090 Thunderbird Lane Fairfield, OH 45014-2234 Dear Mr. Hock: This is in response to your January 16, 2007 letter regarding selective testing of packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you § 178.601(g) (2). ask if partition dividers may be added to a packaging tested in accordance with Variation 2 under The answer is yes, provided the dividers do not replace any integral cushioning material present type in an outer packaging without retesting if the specific conditions of the variation are met. in the original testing of the packaging design type. Variation 2 allows inner packagings of any Therefore, as long as the conditions in § 178.601(g)(2) are met, the addition of dividers does not require further testing. I hope this information is helpful. If you have further questions, please do not hes tate to contact Sincerely Hattie L. Mitchell Office of Hazardous Materials Standards Chief, Regulatory Review and Reinvention 178.601g) (2) 070009#
Page 2Pollack $178.601(g)z) gh Package gh & Product Testing Testing and 07-0009 Consulting, Inc. Mr. H. Perry Hock Technical Director gh Package & Product Testing 1090 Thunderbird Lane and Consulting, Inc Fairfield, OH 45014-2234 Don, Question regarding a 4GV from a customer: o cushioning between the bottles, and there was 3 inches of cushioning between th he ship a 18 x 18 inch box - the pack passed with 9 bottles in the center. There is wa bottles and the exterior. Top view look like this from the top: It would actually increase the filling between the bottles an Can they use a 4 x 4 divider, filling the void spaces with the same cushioning, that woul the exterior wall from 3" to just under 4 ½½" Partition not present during testing Thanks, H. Perry Hock gh Package & Product, Testing and Consulting, Inc. 513.870.0080 ext 103#
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