Non-hazardous materials in sample packagings
Pipeline and Hazardous Materials Safety Administration · Nov 19, 2007 · Reference No. 07-0153
Interprets: 49 CFR § 178.602
Reggie’s quick take
Someone asked whether a non-hazardous material can replace a hazardous one when testing sample packagings. The agency says yes under § 178.602(c), but only if the substitute has similar physical characteristics, including the same or higher specific gravity, as the hazardous material the packaging will hold. For drop tests on certain plastic packagings under § 178.603(c), the contents must be cooled to -18° C or lower and kept liquid. If antifreeze is needed to keep the test liquid from freezing, a water/antifreeze solution with a specific gravity of at least 0.95 is acceptable. If antifreeze is not needed for that purpose, the § 178.602(c) rule on non-hazardous substitutes still applies.
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 responds to your August 7, 2007 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) requirements applicable to packaging test samples. Specifically, you ask about the requirements for using a non-hazardous material in place of a hazardous material when testing sample packagings.
Section 178.602(c) authorizes the use of non-hazardous materials in sample packagings that will be tested in accordance with Subpart M of Part 178 of the HMR. The non hazardous material must have similar physical characteristics, including the same or higher specific gravity, to the hazardous material for which the packaging will be used.
Requirements for conducting the drop test are specified in § 178.603. Paragraph (c) of this section addresses preparation for the drop test of certain types of plastic packagings. In accordance with this paragraph, packagings must be tested when the temperature of the sample packaging and its contents has been reduced to -18° C or lower. Test liquids must be kept in the liquid state. If necessary to ensure that the test liquid remains in a liquid state, anti-freeze may be added to the test liquid. In this situation, water/anti-freeze solutions with a minimum specific gravity of 0.95 for testing at -18° C or lower are acceptable test liquids. Note that the specific gravity specified in § 178.603(c) applies only when the use of a water/anti-freeze solution is necessary to ensure that the test liquid remains in a liquid state. If the use of a water/anti-freeze solution is not necessary to ensure that the material remains in a liquid state, the requirements specified in § 178.602(c) applicable to the use of non-hazardous materials for testing sample packagings apply.
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.