Interpretation Response #08-0286 ([Packaging Applications for Dangerous Goods, LLC] [Mr. David Gluntz])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Packaging Applications for Dangerous Goods, LLC
Individual Name: Mr. David Gluntz
Location State: OH Country: US
View the Interpretation Document
Response text:
February 4, 2009
Mr. David Gluntz
Packaging Applications for Dangerous Goods, LLC
3583 Blackbottom Court
Columbus, OH 43221-4501
Ref No. 08-0286
Dear Mr. Gluntz:
This responds to your November 24, 2008 email requesting clarification of the provisions in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to intermediate bulk containers (IBCs). In your letter, you present two scenarios:
Scenario 1: If the specification markings on an IBC are destroyed, removed, or covered up, is the package still an IBC?
Response 1: Because the specification markings are destroyed, removed, or covered up, the packaging no longer meets the standards of an IBC in accordance with the HMR. The packaging in your scenario is a non-specification bulk packaging.
Scenario 2: The only specification marking on a packaging is a serial number. The serial number was traced back to a packaging manufacturer who states the packaging was manufactured as a United Nations (UN) standard IBC. Must the packaging, originally a UN standard IBC, be retested in accordance with § 180.352?
Response 2: The answer is no. The packaging in your scenario is not required to be retested in accordance with § 180.352. As required in § 180.352, each IBC constructed in accordance with a UN standard for which a test or inspection specified in paragraphs (b)(1), (b)(2) and (b)(3) of
§ 180.352 is required may not be filled and offered for transportation or transported until the test or inspection has been successfully completed.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
180.352
Regulation Sections
| Section | Subject |
|---|---|
| 180.352 | Requirements for retest and inspection of IBCs |