PHMSA letter of interpretation

Table of Packing Methods

Pipeline and Hazardous Materials Safety Administration · Oct 19, 2009 · Reference No. 09-0200

Interprets: 49 CFR § 173.62

Reggie’s quick take

A company asked whether UN 4G fiberboard boxes were still allowed under Packing Method 134 in the § 173.62(c) Table of Packing Methods. The asker noticed they had dropped off the list after a 2008 rule added UN 4H1 expanded plastic boxes, and wondered if that was a printing error. PHMSA said yes: UN 4G fiberboard boxes remain authorized for continued use under Packing Method 134, and the omission was a mistake that the agency has since corrected in a later rulemaking.

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 August 26, 2009 e-mail to this agency concerning a miscellaneous final rule we issued under Docket No. PHMSA-2005-21812 (HM-218D) (01/28/08; 73 FR 4699) that revised requirements for packaging explosive materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You note that on page 4717, in the § 173.62(c) Table of Packing Methods, column 3 of the final rule we amended the HMR to add UN 4H1 expanded plastic boxes as authorized packagings under Packing Method 134. You also note in your e-mail that while this amendment is reflected in the current HMR, the Government Printing Office (GPO) appears to have removed UN 4G fiberboard boxes as authorized packagings from the same list without instruction to do so. You ask if the removal of UN 4G fiberboard boxes from the list of authorized packagings was inadvertent and, if so, are they authorized for continued use under Packing Method 134.

The answer to both of your questions is yes. Continued use of a UN 4G fiberboard box under Packing Method 134 remains authorized. We corrected this inadvertent error in a recent rulemaking; see enclosure.

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.