Variation 2; Lighters
Pipeline and Hazardous Materials Safety Administration · Jun 17, 2005 · Reference No. 05-0141
Interprets: 49 CFR § 178.601(g)
Reggie’s quick take
Someone asked whether Variation 2 in § 178.601(g) applies to butane-filled lighters, which are Division 2.1 flammable gas. It does not, so the asker's understanding was correct. Lighters in approved inner packagings must go in listed outer boxes, such as wooden, plywood, fiberboard, or plastic boxes, that passed design testing at Packing Group II or higher (Special Provision N10, § 172.102). Under § 178.601(g), the mix of lighter and inner packaging setups may change without new design testing, if equivalent performance is kept.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your June 3, 2005 letter regarding the selective testing variations under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if Variation 2 in § 178.601(g) applies to Division 2.1 materials (e.g., butane filled cigarette lighters).
You are correct in your understanding that Variation 2 applies to combination packagings designed and tested to contain liquids or solids and does not apply to flammable gases. In accordance with Special Provision N10 of § 172.102, lighters in their approved inner packagings must be packaged in one of the following outer packagings that have been design qualified tested at the Packing Group II performance level or higher: (1) 4C1 or 4C2 wooden boxes; (:2) 4D plywood boxes; (3) 4F reconstituted wood boxes; 4G fiberboard boxes; or (5) 4H1 or 4H2 plastic boxes. Under § 178.601(g), it is permissible to vary the number and type of approved lighter/inner packaging configurations that are packed in an outer UN standard packaging without further design qualification testing of the package, provided an equivalent level of performance is maintained.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.