Package Research Laboratories — Hazardous Materials Safety Interpretation

Page 1• a of Transportation U.S. Department MAR 2Z 1999 passengion. D.C. 2590 Research and Washington, D.C. Special Programs Administration Ms. Sue E. Pelletier-Bruno 41 Pine Street Package Research Laboratories Ref. No: 99-0005 Rockaway, NJ 07866 Dear Ms. Pelletier-Bruno: This responds to your letter of February 17, 1999, and your conversation with Ms. Diane LaValle of this office concerning requirements for țesting specification packagings under the Hazardous Materials Regulations (HMR; 49 CER Parts 171-180). Specifically, you ask for confirmation that testing is not considered complete until a test report has been prepared, dated, and signed. Your understanding, is correct. , completed for each packaging design qualification test and A test report must be . forth each periodic retest. Section 178.601 (1) of the HMR sets the information that must be included in each test report. The test report may not be signed and dated until all the required information is compiled and finalized. Completion of a test report is the final step in the packaging design qualification testing or periodic retesting process; thus, no specification packaging may be manufactured for sale or use until a report documenting successful completion of all required tests has been completed. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Thomas G. Allan Senior Transportation Regulations Specialist Office of Hazardous Materials Standards 178,601#

Page 299-0005 < 85178-601 Gorsky orig) PRL PACKAGE RESEARCH LABORATORY Division of Stapling Machines Co., LLC 4 41 Pine Street, Rockaway, New Jersey 07866 February 17, 1999 Ms. Diane LaValle 400 7th Street South West US Dept. of Transportation Room 8102 RSTA-DHM-10 Washington DC, 20590 Dear Diane: Thank you for taking the time to review our question today. The head of our lab has requested that we get the answer in writing. I appreciate your time and have repeated the situation below: We tested combination packages of Corrugated Fibreboard containers and plastic or glass bottles tests were completed in December, however the suppliers of their plastic and glass were not able to get under the provisions of Title 49, Code of Federal Regulations, Section 107.404 (49CFR). The physical the gathering of specifications and approval certificate. the specifications to us until February. Therefore, the cartons were held up awaiting the completion of As per our conversation on February 17, 1999 you indicated that the tests were not complete until the specifications were compiled and we should put that date on the test date area of the report. I want to clarify that the customer has not been able to manufacture cartons while awaiting the completed reports. Thank you for your prompt attention and we look forward to receiving your responce. Sincerely, Jue E. Bruno Sue E. Pelletier-Bruno Package Research Laboratories (973) 627-4400 FAX (973) 627-5355 :#

Page 3SEARCH Y PRL PACKAGE RESEARCH LABORATORY Dvision of Stapling Machinee Co., LLC 41 Pine Street, Rockaway, New Jersey 07866 Gorsky February 17, 1888 8178.601 US Dept. of Transportation Ms. Diane LaValle 99-0005 400 7th Street South West Room 8102 RSTA-DHM-10 Washington DC, 20580 Dear Diane: • Thank you for taking the time to review our question today. The head of our lab has requested that we get the answer in writing. I appreciate your time and have repeated the situation below: We lested combination packages of Corrugated Fibreboard containers and plastic or glass bottles under the provisions of Title 48, Code of Federal Regulations, Section 107.404 (49CFR). The physical ests were completed In December, however the suppliers of their plastic and glass were not able to ge the gathering of specifications and approval certificate. ne speciations to us until February. Therefore, the cartons were held up awaiting the completion of specifications were compiled and we should put that date on the test date area of the report. I want to As per our conversation on February 17, 1989 you indicated that the tests were not complete untll the clarify that the customer has not been able to manufacture cartons while awaiting the completed reports. Thank you for your prompt attention and we look forward to receiving your responce. Sincerely, Susan- Nue E. BranD Per EC 4 the tet Sue E. Pelletier-Bruno Package Research Laboratories _ VEceived (973) 627-4400 FAX (973) 827-5355 zid 120:1 66 11 831#

Page 4% Date: Wednesday, February 17, 1999 To: US Dept of Transportation Ms. Diane La Valle Phone: 202-366-6344 Fax: 202-366-3012 From: Package Research Laboratory Sue E. Pelletier-Bruno Phone: 973-627-4400 Fax: 913-627-4400 Pages: 2. Subject: This is the letter dealing with the late specifications.. THANK YOU ) I'd 14 1090 6 2 832#

Page 5.i.. Interpretation Letters Requester Sue E. Pelletier-Bruno Date Received: 1/5/99 Company Package Research Laboratory Tracking Number: 99-0005 Phone 973-627-4400 Revision Date: 2/24/99 Date Assigned 2/24/99 Date of Letter 2/17/99 Staff Gorsky First Draft Due: 3/17/99 Section 178.601 First Draft Date: Subject Packaging Specs Concurrence Status Status Date Sign Date Signor HBP Copy to Docket D Copy to DHM-60 D Comment :#

Page 6iPRE Division of Stapling Machines Co. ·15 112.63 PACKAGE RESEARCH LABORATORY TAINE CETHINGE C 41 Pine Street, Rockaway, NJ 07866 US DepT. OK TRANS pOrTATION 400 7th Street South West RSTA-DAM-10 ROOm 8102 WASHiNGtON, DE 20590#