PHMSA - FAQs - 49 CFR 171.8 and 171.23

49 CFR 171.8 and 171.23

Questions posed in UN Third Party Certification Agencies Meetings

§ 171.8: If a packaging consists of an outer fiberboard box with an inner plastic bladder bag that may be emptied either through an opening in the packaging or by removing the bag, hanging it on a hook, and dispensing the liquid contents, is it a composite (UN 6HG2) or a combination (UN 4G) packaging?
§ 171.23: Current ICAO regulations now require a UN package identification code as part of the infectious substance packaging marking. Does OHMS anticipate incorporating this requirement into domestic regulations? If so, would these packagings then fall subject to the periodic retest requirements?

§ 171.8: If a packaging consists of an outer fiberboard box with an inner plastic bladder bag that may be emptied either through an opening in the packaging or by removing the bag, hanging it on a hook, and dispensing the liquid contents, is it a composite (UN 6HG2) or a combination (UN 4G) packaging?
A composite packaging is a packaging consisting of an outer packaging and an inner receptacle constructed so that the inner receptacle and the outer packaging form one integral packaging. Once assembled, a composite packaging remains an integrated, single unit – it is filled, stored, shipped, and emptied as a single unit. By contrast, a combination packaging consists of one or more inner packagings secured in a non-bulk outer packaging. The inner packaging of a combination packaging is intended to be removed from the outer packaging for emptying. The inner receptacle for the packaging described in the question above can be used as either an integral component of the packaging or a separate inner packaging of a combination packaging. We consider such a packaging to be a combination packaging because the inner packaging may be removed for emptying. A composite packaging must be filled and emptied as a single unit. [Answered in June 2000 Performance-Oriented Packaging Meeting in Chicago]
§ 171.23: Current ICAO regulations now require a UN package identification code as part of the infectious substance packaging marking. Does OHMS anticipate incorporating this requirement into domestic regulations? If so, would these packagings then fall subject to the periodic retest requirements?
OHMS plans to propose to adopt the package identification code for infectious substance packagings in a notice of proposed rulemaking in late 1998. If the provisions are adopted into the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), infectious substance packagings would be subject to requirements in Subpart M of Part 178 for design qualification testing and periodic retesting, including test record retention. [Answered Sept 25, 1998 from a series of questions posed to the RSPA]