IIA Test Verification and Witnessing Requirements

January 21, 2026

Reference No. 25-0100

This letter is in response to your July 16, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging testing, witnessing, and verification. Specifically, you ask whether recordings of testing satisfy witnessing requirements?

We have paraphrased and answered your questions as follows:

Q1. Can the use of camera systems or structured data collection submitted to an Independent Inspection Agency (IIA) satisfy the witnessing obligations of §§ 178.35 and 178.70 under International Organization for Standardization (ISO) and Department of Transportation (DOT) specifications?

A1. No. The testing must be witnessed by the IIA at the time of testing, physically present at the location of testing. Submitting recorded material would not satisfy the requirements of the HMR for IIA witnessing and test verification.

Q2. If these systems are allowable, what protocols or controls would need to be in place to ensure such technology-supported submission maintains the standard of objectivity, traceability, and technical rigor required by the standards?

A2. See A1.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Alexander Wolcott
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

§ 178.35, § 178.70