# Gh Package/Product Testing and Consulting, Inc. — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 13-0091
- **title:** Gh Package/Product Testing and Consulting, Inc. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2013-07-31
- **effective on:** Not available
- **summary:** 13-0091 response to Gh Package/Product Testing and Consulting, Inc. concerning 178.516, 178.603.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0091.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0091.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-13-0091
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130091.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
JUL 3 1 2013
Mr. Ronald .T. Sorrell
Gh Package/Product Testing and Consulting, Inc.
4090 Thunderbird Lane
Fairfield, OH 45014
RefNo.: 13-0091
Dear Mr. Sorrell:
This is a response to your April 30, 2013 email requesting clarification of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 1 00-185) with regard to the assembly of a UN 4G
fiberboard box. Specifically, you seek clarification on the criteria for passing the drop test
specified in§ 178.603.
In your incoming email you describe a telescoping box with a loaded base and a top that
slides over the base. The box is assembled both with and without a band or tape around the
girth of the closed packaging. This packaging has been tested in accordance with the design
qualification testing specified in Part 178 Subpart M and in both configurations successfully
passed all required tests, including the drop test in§ 178.603. However, for the assembled
box not secured by a band or tape around the girth, you observe that after the drop test, the top
portion of the telescoping box is raised 2-3 inches with no release of product. You question
whether the raised lid after the drop test constitutes a closed packaging.
The answer is yes. Provided there is no release of contents from the packaging and the
packaging passes all applicable UN Specification tests, this would be permissible. It should
be noted that the standards for fiberboard boxes in § 178.516(b )(5) require that boxes must be
designed so as to provide a snug fit to the contents. The drop test described above may be an
indication that the assembled box not secured by a band or tape around the girth does not meet
the intent of§ 178.516(b)(5).
1 hope this information is helpful. If you have any more questions, please do not hesitate to
contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division

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<<<PAGE 3>>>

Drakeford, Carolyn (PHMSA)
From:
Sent:
To:
Subject: Lima, Anthony (PHMSA)
Tuesday, April 30, 2013 9:40AM
13- OOCf I
Drakeford, Carolyn (PHMSA)
Request for Clarification from gh Package I Product Testing and Consulting, Inc.
Carolyn,
Please log Ron Sorrell's question below as a request for written clarification. Ben Moore thinks it's best to hash
this issue out.
Thanks
Anthony Lima
Packaging Program Manager/Senior Investigator
Office Of Hazardous Materials Safety
Field Operations
U.S. DOT/PHMSA
(856) 265-3054 (mobile)
(302) 336-9693 (e-fax)
anthony.lima@dot.gov
website: hazmat.dot.gov
From: Moore, Benjamin (PHMSA)
Sent: Tuesday, April 30, 2013 9:32 AM
To: Lima, Anthony (PHMSA)
Cc: Ron Sorrell
Subject: RE: Telescoping box closure
Anthony and Ron,
I can't find anything that might cover this other than 178.516(b)(S) which states "Boxes must be designed so as to provide
a snug fit to the contents," which it doesn't sound like it's really doing except that it's only occurring during a test. I would
say a clarification from Standards might not be a bad idea, since I have a hard time saying this is not complying with the
HMR.
Benjamin Moore
General Engineer
Office of Hazardous Materials Technology
PHONE: (202) 366-4545
FAX: (202) 366-3650
From: Lima, Anthony (PHMSA)
Sent: Tuesday, April 30, 2013 9:21 AM
To: Moore, Benjamin (PHMSA)
Cc: Ron Sorrell
Subject: RE: Telescoping box closure
Ben,
1

<<<PAGE 4>>>

Ron's question below is probably best answered by other than field ops. If you think this should be handled as a
request for clarification, we can forward the email to Standards instead. Please advise.
Thanks
Anthony Lima
Packaging Program Manager/Senior Investigator
Office Of Hazardous Materials Safety
Field Operations
U.S. DOT/PHMSA
(856) 265-3054 (mobile)
(302) 336-9693 (e-fax)
anthony.lima@dot.gov
website: hazmat.dot.gov
From: Ron Sorrell [mailto:rsorrell@ghtesting.com]
Sent: Tuesday, April 30, 2013 9:18AM
To: Lima, Anthony (PHMSA)
Subject: Telescoping box closure
Hello Mr. Lima
I have a customer who uses a full telescoping box which ships hazmate material. He assembles the box with a loaded
base and then slides the top over the base. A band is put around the girth of the closed telescoping box as a security seal.
If not all the product is used, a piece of tape is put on the top and base to hold lid in place for return. We currently test the
telescoping box with the band and the tape and put both in the report.
Now the customer wants to send the telescoping box with a load in it with no banding or tape at all. He does not want to
use anything for the closure besides the lid of the telescoping box. We tested the telescoping box without any bands or
tape and the lid wants to raise 2"-3" up the base as a result from the drops. So my question is "Does the lifting of the lid of
the telescoping box 2"-3" after drop considered closed or open".
By the CFR 49 drop testing for non-bulk, the product is not exposed and the box is not ripped opened but what gets to me
is the lid is a little less than half way up the base. Does this constitute a closed box?
Thank you for your time.
ftONALJ) J., SORR<RtL
"'
gh Package I Product Testing and Consulting,lnc.
4090 Thunderbird Lane 1 Fairfield, OH 145014 (Click For Directions)
Phone: +(1) 513-870-0080 Ext. 1121 Mobile: +(1) 937-301-9920
2

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Email:rsorrell@ghtesting.com 1 Website: www.ghtesting.com
Testing Facility Service Offerings:
Distribution (ASTM I ISTA) Testing 1 Environmental/ Thermal Testing 1 UN/DOT Testing I lATA 650 I Data Acquisition
Packaged Products upto 8000 lbs.
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This electronic message transmission contains information from gh Package & Product Testing
and Consulting, Inc. which may be confidential or privileged. The information is intended to
be for the use of the individual or entity named above. If you are not the intended recipient,
be aware that any disclosure, copying, distribution or use of the contents of this information
is prohibited. If you have received this electronic transmission in error, please notify us by
telephone (1-513-870-0080) or by electronic mail (rsorrell@ghtesting.com) immediately.
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