# All Star Corrugated — Hazardous Materials Safety Interpretation

- **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:** Not available
- **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:**

<<<PAGE 1>>>

U.S. Department of Transportation Pipeline and Hazardous Materials
Safety Administration
MAY 2 0 2009
1200 New Jersey Ave, S.E.
Washington, D.C. 20590
Ms. LaDonna Anthony
All Star Cormgated
1425 Forum Way So.
Fort Worth, TX 76140
Ref. No. 09-0059
Dear Ms. ~ n t h o n ~ :
This responds to your March 3,2009 request for clarification of package certification
requirements under the Hazardous Materials Regulations (HNIR, 49 CFR Parts 17 1 - 1 80).
Specifically, you ask if your company may use the current certification from another box
manufacturer as long as you follow the current specifications.
According to your letter, your company is going to manufacture UN 4G boxes utilizing a
design that has been tested and certified by a different manufacturer. It is your understanding
that your company may use the other box manufacturer's certification for the boxes you
manufacture provided the boxes conform to the design specifications as certified by the
original manufacturer.
You may use the test report for the package, but must mark the box with your name or
symbol identifying you as the manufacturer of the box. In order to continue using the third-
party lab mark, you must either receive authorization from the third-party certifying the
package or submit the package for testing with the original third-party lab.
I hope this answers your inquiry.
Sincerely,
Charles E. Betts
Standards Development
of Hazardous Materials Standards

<<<PAGE 2>>>

Page 1 of 3
Drakeford, Carolyn <PHMSA>
- ... . ----"* ,-- ---- **-- * -*em.--w.- -*<.- . - -.- -"-. *-" * ~
From: Boothe, Deborah <PHMSA>
Sent: Tuesday, March 17,2009 9: 12 AM
To: LaDonna Anthony
Cc: Boothe, Deborah <PHMSA>; Drakeford, Carolyn <PHMSA>
Subject: RE: UNIIMDG Box Certifications
Importance: High
Hi LaDonna,
Thank you for the information! It's very helpful! It would also be helpful if you could be more specific regarding the
type of explosive devices, e.g. UN number, proper shipping name, etc., that will be packaged in these packages.
Thank you again! Hope you're having a great day!
Deborah Boothe
DOTIPHMSAlOfice of Hazardous Materials StandardsIPHH-10
202-366-8553
From: LaDonna Anthony [mailto:ladonna.anthony@sbcglobal.net]
Sent: Friday, March 13, 2009 4:37 PIY
To: Boothe, Deborah <PHMSA>
Subject: RE: UNIIMDG Box Certifications
Hello Deborah,
We would like to manufacture shipping boxes for a company that makes shape charges for the oil field
industry. They are explosive devices for underground drilling. We made their boxes for years and then
lost the business to a competitor. Now we are getting some of it back. Some of the boxes are in the
"middle" of a certification. That is, there are several months left until re-certification is required. I have
been told that we can use the current certs from the other box manufacturer as long as we follow the
specs, which of course we would. I need a letter from you stating that it is allowed. The boxes are RSC,
275# Double Wall with Michelman coating. An example of the cert. would be UN 4GlY3lSl2009
USA/+AQ 1493
Let me know if you need more info.
Thanks for your help!
LaDonna
LaDonna Anthony
All Star Corrugated
81 7-454-8665
ladonna @allstarbox. corn
--- On Wed, 3/11/09, deborah.boothe@dot.gov cdeborah.boothe@dot.gov> wrote:
From: deborah.boothe@dot.gov <deborah.boothe@dot.gov>
Subject: RE: UN/IMDG Box Certifications
To: ladonna.anthony@sbcglobal.net
Cc: carolyn.drakeford@dot.gov, deborah.boothe@dot.gov

<<<PAGE 3>>>

Page 2 of 3
Date: Wednesday, March ll,2009,2:01 PM
Good afternoon,
I have been assigned to prepare your letter of interpretation re: UNllMDG certifications. I will need more
specific information in order to prepare your letter. Will you please provide me with additional information,
such as, type of package, package spec, type of explosive devices shipped in these packages, weight
shipped, more specific information on the current certification for All Star Corrugated, etc.
Thank you.
Deborah Boothe
Transportation Regulations Specialist
DOTlPHMSAlOffice of HazMat StandardsIPHH-I 0
202-366-8553
From: Drakeford, Carolyn <PHMSA>
Sent: Wednesday, March 11, 2009 2:46 PM
To: Boothe, Deborah <PHMSA>
Subject: FW: UN/:[MDG Box Certifications
From: INFOCNTR <PHMSA>
Sent: Wednesday, March 04, 2009 8:26 AM
To: Drakeford, Carolyn <PHMSA>
Subject: MI: UN/IMDG Box Certifications
Carolyn,
Thanks,
Rob
4 request for a written interpretation. See below.
From: LaDonna Anthony [mailto:ladonna.anthony@sbcglobal.net]
Sent: Tuesday, March 03, 2009 2:46 PM
To: INFOCNTR <PHMSA>
Subject: Fw: LIN/IMDG Box Certifications
LaDonna Anthony
411 Star Corrugated
91 7-454-8665
~adonna@allstarbox. corn
--- On Tue, 3/3/09, LaDonna Anthony <ladonna.anthony@bcglobal.net> wrote:
From: LaDonna Anthony <ladonna.anthony@sbcglobal.net>
Subject: UNIIMDG Box Certifications
To: infocnter@dot.gov
Date: Tuesday, March 3,2009,7:44 PM
Dear Sirs,
Thank you in advance for your help on this matter.

<<<PAGE 4>>>

Page 3 of 3
We are requesting a written letter of interpretation regarding the use of UNIIMDG certifications. All
Star Corrugated is a manufacturer of corrugated shipping boxes. We currently produce many certified
boxes for various explosive device manufacturers. We are in pursuit to re-gain the business of a past
customer and provide them with boxes. We need to assure them that we can use their current
certification. Of course, we know to follow exactly the specifications that are outlined in the
certification. Please let me know if there is anything else you need from me.
You can mail the letter of interpretation to:
All Star Corrugated
1425 Forum Way So.
Fort Worth . TX 76 140
Attn: LaDonna Anthony
LaDonna Anthony
All Star Corrugated
81 7-454-8665
ladonna@allstarbox.com
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