Cushioning Material in Variation 2 Packagings

This responds to your June 22, 2001 letter requesting clarification of requirements for cushioning material used in packagings manufactured in accordance with Variation 2 in § 178.601 (g)(2) of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180).

Specifically, you asked if your understanding is correct that cushioning material used in Variation 2 packagings must be such that: 1) the thickness of cushioning material surrounding each inner packaging is at least as great as the thickness of the cushioning material in the originally tested packaging; 2) if the inner packagings contain liquids, the absorbent material. must be capable of absorbing the entire liquid contents of the inner packaging, and must be placed in a leakproof liner; 3) the cushioning material must be compatible with the contents of the inner packagings; and 4) any suitable cushioning material may be used, if it meets the requirements of items I through 3 above, and the gross weight of the completed packaging does not exceed the marked gross weight of the packaging certified under Variation 2.

Your understanding is correct. In accordance with the requirements for packagings under Variation 2, as specified in § 178.601(g)(2), the thickness of cushioning material between inner packagings and between inner packagings and the outside of the packaging may not be reduced below the corresponding thickness in the originally tested packaging. When a single inner packaging was used in the original test, the thickness of cushioning between inner packagings may not be less than the thickness of cushioning between the outside of the packaging and the inner packaging in the original test. When either fewer or smaller inner packagings are used, sufficient additional cushioning material must be utilized to take up void spaces.