Hedwin Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 JAN 2 7 2014 Ms. Cheryl Defelice Hedwin Corporation 1600 Roland Heights A venue Baltimore, MD 21211 Ref. No. 13-0201 Dear Ms. Defelice: This responds to your October 25, 2013 request for clarification on the periodic retesting requirements for a 4GV non-bulk combination packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, your 4GV non-bulk combination packaging has been selectively tested under Variation 1 specified in§ 178.601(g)(l). You seek further clarification on a previously issued letter of interpretation (Ref No 08-031 0) as it relates to your packaging. Your questions are paraphrased and answered as follows: Q 1 .. Is it necessary to conduct a periodic retest on each closure method that was previously tested during the design qualification test for the 4GV combination packaging? A 1. The answer is no. You may maintain a single test record and report identification number for identical packaging that differ only in method of closure, provided each method of closure is documented in the test report and the packaging successfully passes the required tests when closed in accordance with each closure method identified in the test report. Selective testing of combination packaging under Variation 1 is authorized for 4GV combination packaging in accordance with § 178.601(g)(l). Q2. Is it possible to test just one of the closure methods documented in the report? A2. The answer is yes. In accordance with Variation 1 in§ 178.601(g)(l)selective testing is permitted provided inner closures are of similar design and an equivalent level of performance is maintained. I hope this answers your inquiry. If you need additional assistance, please call this office at (202) 366-8553. Sincerely, ;(k 0Jtxr Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2An EmptQ\I,·e-Ownea Company CORPORATION 1600 ROLAND HEIGHTS AVENUE, BALTIMORE, MD 21211 410-467-8209 • FAX 410-467-1761 May21, 2012 To Whom It May Concern: This letter is written to request written clarification of a DOT Interpretation as attached #08-031 0. In this letter it was stated that one is not required to have separate packaging test records and separate report identification numbers for combination packagings that are identical except for closure method. Each closure method must be documented and tested. My question concerns periodic retesting of the test report. Is it necessary to conduct a periodic retest on each closure method once the design report is issued? Or is it possible to test just one of the dosure methods documented in the report? Sincerely, ~ !lou.~,____, Susan R. Nauman Technical Service Supervisor SRNicld Attached: #08-031 0 Corporate Office and Plant 1600 ROLAND HEIGHTS AVE. BALTIMORE, MARYLAND 21211 410-467-8209 FAX 410-467-1761 California Office and Plant 22418 S. BONITA STREET CARSON, CALIFORNIA 90745 310-834-4571 FAX 310-834-9473#

Page 3PHMSA ~Interpretations by Regulation ~ Interpretation #08-031 0 . . ___.. Page I of2 Carc:.ers I Contact Us I FAQs I Site Map • ------------Ad¥~-.-n-ced-~Sea~h For the Public About Us Calendar Contact Us Data a Statistics Electronic Services Enforcement Grants Hazardous Materials Information Center Incident Reporting International Standards Interpretations Library NTSB Safety Recommendations Registration Regulations Risk Management S.afety Advisory Notices Security Special Permits a. Approvals Training 8r. Outreach Media Congress Doing Business with Home » Hazmat Safety Community » Regulations » InterPretations » Interpretations by Regulation PHMSA lnterpietation #08..031 0 Feb4,2009 PHMSA Response Letter PDFV<~Jrsion Regulation References: 49 CFR 178.601 More Interpretations on this topic Read the Regulation February 4, 2009 Mission and Goals About the Agency IWy Ol'f"JCials Organization Calendar P,J:omb.tihQ Safety &-s~cujrtY Regulatio- Speci:ll Permits &t Approvals International standords Security Initidives Mr. John Fosse VIce· President-sales 1819 W. Harry Street Wichita, KS 67213 Ref. No. 08-D310 Dear Mr. Fosse: This responds to your November 20, 2008 letter requesting darification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171·180). Specifically, you ask If you are required to have separate packaging test records and separate report identification numbers for combination packagings that are identical {i.e., the same inner packagings, the same outer packaging and the same packaging configuration) except for closure method (e.g., one is closed using 2-inch tape while another is closed using glue). The answer is no. You are required to maintain a record of each design qualification test In accordance with § 178.601(1). The test record must include a description of the packaging design type, including methods of dosure. You may maintain a single test record and test report identification number for identical packagings that differ only in method of closure, provided each method of closure is documented in the test report and the packaging successfully passes the required tests when closed in accordance with each closure method Identified in the test report. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, Olarles E. Betts Chief, Standards Development Office of Hazardous Materials Standards 178.601(1) OMS ID# 08-0310 http://www.phmsa.dot.gov/portallsite/PHMSA/menuitem.ebdc7a8a7e39f2e55cf203105024... 5/1 I/2009#