{"operation":"document","citation":"99-0005","title":"Package Research Laboratories — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-03-22","effective_on":null,"summary":"99-0005 response to Package Research Laboratories concerning 178.601.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990005.pdf","body":"<<<PAGE 1>>>\n\n• a\nof Transportation\nU.S. Department\nMAR 2Z 1999\npassengion. D.C. 2590\nResearch and\nWashington, D.C.\nSpecial Programs\nAdministration\nMs. Sue E. Pelletier-Bruno\n41 Pine Street\nPackage Research Laboratories\nRef. No: 99-0005\nRockaway, NJ 07866\nDear Ms. Pelletier-Bruno:\nThis responds to your letter of February 17, 1999, and your\nconversation with Ms. Diane LaValle of this office concerning\nrequirements for țesting specification packagings under the\nHazardous Materials Regulations (HMR; 49 CER Parts 171-180).\nSpecifically, you ask for confirmation that testing is not\nconsidered complete until a test report has been prepared,\ndated, and signed.\nYour understanding, is correct.\n, completed for each packaging design qualification test and\nA test report must be .\nforth\neach periodic retest.\nSection 178.601 (1) of the HMR sets\nthe information that must be included in each test\nreport. The test report may not be signed and dated until all\nthe required information is compiled and finalized.\nCompletion of a test report is the final step in the packaging\ndesign qualification testing or periodic retesting process;\nthus, no specification packaging may be manufactured for sale\nor use until a report documenting successful completion of all\nrequired tests has been completed.\nI hope this information is helpful. If you have further\nquestions, please do not hesitate to contact this office.\nSincerely,\nThomas G. Allan\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n178,601\n\n<<<PAGE 2>>>\n\n99-0005\n<\n85178-601 Gorsky\norig)\nPRL\nPACKAGE RESEARCH LABORATORY Division of Stapling Machines Co., LLC\n4\n41 Pine Street, Rockaway, New Jersey 07866\nFebruary 17, 1999\nMs. Diane LaValle\n400 7th Street South West\nUS Dept. of Transportation\nRoom 8102\nRSTA-DHM-10\nWashington DC, 20590\nDear Diane:\nThank you for taking the time to review our question today. The head of our lab has requested that\nwe get the answer in writing. I appreciate your time and have repeated the situation below:\nWe tested combination packages of Corrugated Fibreboard containers and plastic or glass bottles\ntests were completed in December, however the suppliers of their plastic and glass were not able to get\nunder the provisions of Title 49, Code of Federal Regulations, Section 107.404 (49CFR). The physical\nthe gathering of specifications and approval certificate.\nthe specifications to us until February. Therefore, the cartons were held up awaiting the completion of\nAs per our conversation on February 17, 1999 you indicated that the tests were not complete until the\nspecifications were compiled and we should put that date on the test date area of the report. I want to\nclarify that the customer has not been able to manufacture cartons while awaiting the completed reports.\nThank you for your prompt attention and we look forward to receiving your responce.\nSincerely,\nJue E. Bruno\nSue E. Pelletier-Bruno\nPackage Research Laboratories\n(973) 627-4400\nFAX (973) 627-5355\n:\n\n<<<PAGE 3>>>\n\nSEARCH\nY\nPRL\nPACKAGE RESEARCH LABORATORY Dvision of Stapling Machinee Co., LLC\n41 Pine Street, Rockaway, New Jersey 07866\nGorsky\nFebruary 17, 1888\n8178.601\nUS Dept. of Transportation\nMs. Diane LaValle\n99-0005\n400 7th Street South West\nRoom 8102\nRSTA-DHM-10\nWashington DC, 20580\nDear Diane:\n•\nThank you for taking the time to review our question today. The head of our lab has requested that\nwe get the answer in writing. I appreciate your time and have repeated the situation below:\nWe lested combination packages of Corrugated Fibreboard containers and plastic or glass bottles\nunder the provisions of Title 48, Code of Federal Regulations, Section 107.404 (49CFR). The physical\nests were completed In December, however the suppliers of their plastic and glass were not able to ge\nthe gathering of specifications and approval certificate.\nne speciations to us until February. Therefore, the cartons were held up awaiting the completion of\nspecifications were compiled and we should put that date on the test date area of the report. I want to\nAs per our conversation on February 17, 1989 you indicated that the tests were not complete untll the\nclarify that the customer has not been able to manufacture cartons while awaiting the completed reports.\nThank you for your prompt attention and we look forward to receiving your responce.\nSincerely,\nSusan-\nNue E. BranD\nPer EC 4 the tet\nSue E. Pelletier-Bruno\nPackage Research Laboratories\n_ VEceived\n(973) 627-4400\nFAX (973) 827-5355\nzid\n120:1 66 11 831\n\n<<<PAGE 4>>>\n\n%\nDate:\nWednesday, February 17, 1999\nTo:\nUS Dept of Transportation\nMs. Diane La Valle\nPhone: 202-366-6344\nFax:\n202-366-3012\nFrom:\nPackage Research Laboratory\nSue E. Pelletier-Bruno\nPhone: 973-627-4400\nFax: 913-627-4400\nPages:\n2.\nSubject:\nThis is the letter dealing with the late\nspecifications..\nTHANK YOU\n)\nI'd\n14 1090 6 2 832\n\n<<<PAGE 5>>>\n\n.i..\nInterpretation Letters\nRequester\nSue E. Pelletier-Bruno\nDate Received: 1/5/99\nCompany\nPackage Research Laboratory\nTracking Number: 99-0005\nPhone\n973-627-4400\nRevision Date: 2/24/99\nDate Assigned 2/24/99\nDate of Letter 2/17/99\nStaff\nGorsky\nFirst Draft Due: 3/17/99\nSection\n178.601\nFirst Draft Date:\nSubject\nPackaging Specs\nConcurrence\nStatus\nStatus Date\nSign Date\nSignor\nHBP\nCopy to Docket D\nCopy to DHM-60 D\nComment\n:\n\n<<<PAGE 6>>>\n\niPRE\nDivision of Stapling Machines Co.\n·15\n112.63\nPACKAGE RESEARCH LABORATORY\nTAINE CETHINGE C\n41 Pine Street, Rockaway, NJ 07866\nUS DepT. OK TRANS pOrTATION\n400 7th Street South West\nRSTA-DAM-10\nROOm 8102\nWASHiNGtON, DE 20590","truncated":false,"body_characters":5533}