Closure Requirements
Pipeline and Hazardous Materials Safety Administration · Apr 19, 1995 · Reference No. 95-0165
Reggie’s quick take
A company asked whether shrink bands or tape are needed to keep bottle caps from loosening on air shipments of hazardous materials under § 173.27(d). PHMSA said neither is required. Instead, each cap must be tightened enough before shipping that vibration and temperature changes will not loosen it. The § 178.608 vibration standard shows whether extra measures are needed. The letter also told the asker to remove a reference to § 107.404 from its certificate, since the agency has no record of it being an approved third-party certifier.
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 December 27, 1994 letter requesting clarification on closure requirements for packagings containing hazardous materials transported by air in accordance with 49 CFR 173.27(d). You specifically asked if shrink bands or taping the caps is necessary to prevent loosening due to vibration or temperature changes during air shipments.
Adding shrink bands or tape is not necessary to prevent loosening during air shipments. However, you must ensure that each cap is tightened sufficiently before shipment so that vibration and temperature changes will not cause the cap to loosen. The vibration standard prescribed in § 178.608 is a means of determining whether additional measures are necessary to ensure the caps remain tight. You also must ensure that a substantial increase or decrease in temperature will not loosen the cap.
The test report enclosed with your letter contains a reference to § 107.404, which implies that you are a DOT-approved third party certification agency. Because we have no record indicating that you have been approved as a third party certification agency, this reference should be removed from your certificate of compliance.
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.