{"operation":"document","citation":"09-0059","title":"All Star Corrugated — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-05-20","effective_on":null,"summary":"09-0059 response to All Star Corrugated concerning 178.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0059.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0059.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0059","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2009/090059.pdf","body":"<<>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\nMAY 2 0 2009\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nMs. LaDonna Anthony\nAll Star Cormgated\n1425 Forum Way So.\nFort Worth, TX 76140\nRef. No. 09-0059\nDear Ms. ~ n t h o n ~ :\nThis responds to your March 3,2009 request for clarification of package certification\nrequirements under the Hazardous Materials Regulations (HNIR, 49 CFR Parts 17 1 - 1 80).\nSpecifically, you ask if your company may use the current certification from another box\nmanufacturer as long as you follow the current specifications.\nAccording to your letter, your company is going to manufacture UN 4G boxes utilizing a\ndesign that has been tested and certified by a different manufacturer. It is your understanding\nthat your company may use the other box manufacturer's certification for the boxes you\nmanufacture provided the boxes conform to the design specifications as certified by the\noriginal manufacturer.\nYou may use the test report for the package, but must mark the box with your name or\nsymbol identifying you as the manufacturer of the box. In order to continue using the third-\nparty lab mark, you must either receive authorization from the third-party certifying the\npackage or submit the package for testing with the original third-party lab.\nI hope this answers your inquiry.\nSincerely,\nCharles E. Betts\nStandards Development\nof Hazardous Materials Standards\n\n<<>>\n\nPage 1 of 3\nDrakeford, Carolyn \n- ... . ----\"* ,-- ---- **-- * -*em.--w.- -*<.- . - -.- -\"-. *-\" * ~\nFrom: Boothe, Deborah \nSent: Tuesday, March 17,2009 9: 12 AM\nTo: LaDonna Anthony\nCc: Boothe, Deborah ; Drakeford, Carolyn \nSubject: RE: UNIIMDG Box Certifications\nImportance: High\nHi LaDonna,\nThank you for the information! It's very helpful! It would also be helpful if you could be more specific regarding the\ntype of explosive devices, e.g. UN number, proper shipping name, etc., that will be packaged in these packages.\nThank you again! Hope you're having a great day!\nDeborah Boothe\nDOTIPHMSAlOfice of Hazardous Materials StandardsIPHH-10\n202-366-8553\nFrom: LaDonna Anthony [mailto:ladonna.anthony@sbcglobal.net]\nSent: Friday, March 13, 2009 4:37 PIY\nTo: Boothe, Deborah \nSubject: RE: UNIIMDG Box Certifications\nHello Deborah,\nWe would like to manufacture shipping boxes for a company that makes shape charges for the oil field\nindustry. They are explosive devices for underground drilling. We made their boxes for years and then\nlost the business to a competitor. Now we are getting some of it back. Some of the boxes are in the\n\"middle\" of a certification. That is, there are several months left until re-certification is required. I have\nbeen told that we can use the current certs from the other box manufacturer as long as we follow the\nspecs, which of course we would. I need a letter from you stating that it is allowed. The boxes are RSC,\n275# Double Wall with Michelman coating. An example of the cert. would be UN 4GlY3lSl2009\nUSA/+AQ 1493\nLet me know if you need more info.\nThanks for your help!\nLaDonna\nLaDonna Anthony\nAll Star Corrugated\n81 7-454-8665\nladonna @allstarbox. corn\n--- On Wed, 3/11/09, deborah.boothe@dot.gov cdeborah.boothe@dot.gov> wrote:\nFrom: deborah.boothe@dot.gov \nSubject: RE: UN/IMDG Box Certifications\nTo: ladonna.anthony@sbcglobal.net\nCc: carolyn.drakeford@dot.gov, deborah.boothe@dot.gov\n\n<<>>\n\nPage 2 of 3\nDate: Wednesday, March ll,2009,2:01 PM\nGood afternoon,\nI have been assigned to prepare your letter of interpretation re: UNllMDG certifications. I will need more\nspecific information in order to prepare your letter. Will you please provide me with additional information,\nsuch as, type of package, package spec, type of explosive devices shipped in these packages, weight\nshipped, more specific information on the current certification for All Star Corrugated, etc.\nThank you.\nDeborah Boothe\nTransportation Regulations Specialist\nDOTlPHMSAlOffice of HazMat StandardsIPHH-I 0\n202-366-8553\nFrom: Drakeford, Carolyn \nSent: Wednesday, March 11, 2009 2:46 PM\nTo: Boothe, Deborah \nSubject: FW: UN/:[MDG Box Certifications\nFrom: INFOCNTR \nSent: Wednesday, March 04, 2009 8:26 AM\nTo: Drakeford, Carolyn \nSubject: MI: UN/IMDG Box Certifications\nCarolyn,\nThanks,\nRob\n4 request for a written interpretation. See below.\nFrom: LaDonna Anthony [mailto:ladonna.anthony@sbcglobal.net]\nSent: Tuesday, March 03, 2009 2:46 PM\nTo: INFOCNTR \nSubject: Fw: LIN/IMDG Box Certifications\nLaDonna Anthony\n411 Star Corrugated\n91 7-454-8665\n~adonna@allstarbox. corn\n--- On Tue, 3/3/09, LaDonna Anthony wrote:\nFrom: LaDonna Anthony \nSubject: UNIIMDG Box Certifications\nTo: infocnter@dot.gov\nDate: Tuesday, March 3,2009,7:44 PM\nDear Sirs,\nThank you in advance for your help on this matter.\n\n<<>>\n\nPage 3 of 3\nWe are requesting a written letter of interpretation regarding the use of UNIIMDG certifications. All\nStar Corrugated is a manufacturer of corrugated shipping boxes. We currently produce many certified\nboxes for various explosive device manufacturers. We are in pursuit to re-gain the business of a past\ncustomer and provide them with boxes. We need to assure them that we can use their current\ncertification. Of course, we know to follow exactly the specifications that are outlined in the\ncertification. Please let me know if there is anything else you need from me.\nYou can mail the letter of interpretation to:\nAll Star Corrugated\n1425 Forum Way So.\nFort Worth . TX 76 140\nAttn: LaDonna Anthony\nLaDonna Anthony\nAll Star Corrugated\n81 7-454-8665\nladonna@allstarbox.com","truncated":false,"body_characters":5741}