{"operation":"document","citation":"26-0037","title":"Acme Corrugated Box Co., Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2026-06-25","effective_on":null,"summary":"26-0037 response to Acme Corrugated Box Co., Inc. concerning 178.601.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-26-0037.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-26-0037.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-26-0037","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2026-06/26-0037.pdf","body":"<<>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nJune 25, 2026\nMr. Jeff Bittner\nTechnical Sales Representative\nAcme Corrugated Box Co., Inc.\n2700 Turnpike Drive\nHatboro, PA 19040\nReference No. 26-0037\nDear Mr. Bittner:\nThis is in response to your January 21, 2026 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to United Nations (UN)\nspecification packaging. In your email, you describe a scenario involving corrugated boxes\nmanufactured by your company. You state that during recent recertification testing, the testing\nlaboratory identified that the most recent production samples utilized a 42-pound middle liner\ninstead of the 26-pound liner specified in the previous test report. You further state that these\nupgraded boxes—reflecting the new paper combination—were subsequently tested successfully\nas a UN standard package, and a new test report was issued. Specifically, you request written\nacknowledgment that your boxes are approved for use as a UN specification packaging.\nPlease note that PHMSA does not explicitly “approve” standard UN specification packagings. In\naccordance with § 178.601(b), “[i]t is the responsibility of the packaging manufacturer to assure\nthat each package is capable of passing the prescribed tests.” When a change is made to a\npackaging design, such as upgrading the middle liner from 26‑pound to 42‑pound, it may\nconstitute a new or different “design type” under § 178.601(c)(4), which requires design\nqualification testing. Because the test lab successfully tested the new design type containing the\n42-pound liner and documented it in the provided January 7, 2026 test report, the design\nqualification requirements appear to have been met.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nAlexander Wolcott\nActing Chief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<>>\n\n26-0037\nPollack\nFW: UN Certified Carton\nINFOCNTR (PHMSA) To: \"Baker, Yul (PHMSA)\" \nCc: Hazmat Interps \nWed, Jan 21, 2026 at 3:54 PM\nGood afternoon,\nI have called and spoken to Mr. Bittner about this situation and reached out to Ryan Larson for guidance.\nMr. Bittner indicated he wanted a response in writing so I am submitting this interpretation request on his\nbehalf. Let me know if you need anything else.\nBest,\nAminah\nFrom: Jeff Bittner \nSent: Wednesday, January 21, 2026 8:11 AM\nTo: INFOCNTR (PHMSA) \nSubject: UN Certified Carton\nYou don't often get email from jbittner@acmebox.com. Learn why this is important\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments\nunless you recognize the sender and know the content is safe.\nGood morning,\nI have spoken several times with Amina at PHMSA regarding a box that was identified as inconsistent with a previous test\nreport when recertification was underway. I have attached copies of both test reports.\nAmina and I spoke on January 21, at which time she told me that the boxes in question can be used as they are since\nperformance has been validated under the current test report.\nHere are the key points:\n\n<<>>\n\nAcme Corrugated has been making this box for Champion Container for years.\nDuring the recent recertification testing that was completed for the report published earlier this month, box samples\nwere pulled from the most recent production order. T-MAK, the testing lab, identified that the middle liner of the\nbox did not match the previous report . Instead of a 26# liner (tested at 27.4), a 42# liner was used instead\n(heavier than specified). The box was upgraded for some unknown reason.\nThe new report (1/7) reflects the paper combination of the boxes in question, tested successfully as part of the UN\npackage. CO number was 3010 on previous report and is now 4125 on the new one.\nI am requesting acknowledgement in writing that the boxes in question are approved for use. Our customer will need this\nfor their records.\nI appreciate your assistance with this matter. Please let me know if there are any questions. I can be reached by email or\nby contact information below.\nJeff Bittner\nTechnical Sales\nRepresentative\n(direct) 215-444-8049\n(cell) 267-481-3610\nA Century of Innovation and Service\nAcme Corrugated Box Co., Inc.\n2700 Turnpike Drive, Hatboro, PA 19040\nacmebox.com\nThis message and any attachments may contain confidential information and are only for the use of the intended recipient. If you are not the intended recipient, please\nnotify the sender by return email, and delete or destroy this and all copies of this message and all attachments. Any unauthorized disclosure, use, distribution, or\nreproduction of this message or any attachments is prohibited and may be unlawful.\nNothing in this e-mail message shall be deemed to constitute a binding commitment or contract of any offer, or acceptance of any offer, to sell or purchase goods or\nservices unless the message explicitly provides otherwise. The transmission of any document attached to this e-mail message shall not be deemed to imply that a party\nhas signed, adopted or authenticated such document unless it bears a facsimile of such party's handwritten signature or such party has otherwise clearly and expressly\nindicated that it intends to be legally bound by, adopt or authenticate such document. Any quotation, proposal or purchase order attached to this e-mail message that the\nsender has signed or otherwise expressly adopted or authenticated shall have such legal effect as is expressly provided in that attachment.\nNothing in this e-mail message shall be deemed an electronic signature for purposes of the Pennsylvania Uniform Electronic Transactions Act or the federal Electronic\nSignatures in Global and National Commerce (E-SIGN) Act. No employee or agent is authorized to conclude any binding agreement on behalf of Acme Corrugated Box\nCo., Inc. with another party by e-mail without express written confirmation by an authorized officer of our company. In no event will this e-mail message or its content be\nconstrued as written confirmation.","truncated":false,"body_characters":6368}