Interpretation Response #10-0060 ([URS Corporation] [Ms. Erin Jarman])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 04/19/2010

Company Name: URS Corporation

Individual Name: Ms. Erin Jarman

Location State: NC Country: US

View the Interpretation Document

Response text:

April 19, 2010

Ms. Erin Jarman

Environmental Scientist

URS Corporation

1600 Perimeter Park Drive, Suite 400

Morrisville, NC 27560



Ref. No. 10-0060

Dear Ms. Jarman:

This responds to your March 16, 2010 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to Intermediate Bulk Containers (IBCs). Specifically, you ask for clarification of the language in § 180.352(b)(2)(iii) that states, "The inner receptacle of a composite IBC must be removed from the outer body for inspection unless the inner body is bonded to the outer body or unless the outer body is constructed in such a way (e.g., a welded or riveted cage) that removal of the inner receptacle is not possible without impairing the integrity of the outer body." Your questions are summarized and answered as follows:

Q1) Would an inner body of a composite IBC that is secured into the outer body by straps that are welded and that would require cutting have to be removed from the outer body for inspection?

A1) No. The HMR do not require attachments that are welded to the outer body to be removed prior to inspection.

Q2) Would an inner body of a composite IBC that is secured into the outer body by straps that are crimped and that would require cutting have to be removed from the outer body for inspection?

A2) Yes, provided cutting the crimped attachments would not affect the integrity of the outer body.

Q3) Would an inner body of a composite IBC that is secured into the outer body with straps having bolted fasteners have to be removed from the outer body for inspection?

A3) Yes, provided removal of the inner body would not affect the integrity of the outer body.

I hope this information is helpful. If you have further questions, please contact this office.

Sincerely,

Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

180.352(b)(2)(iii)

Regulation Sections