Interpretation Response #16-0173 ([Andax Industries LLC.] [Mr. Patrick McAtarian])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Andax Industries LLC.
Individual Name: Mr. Patrick McAtarian
Location State: KS Country: US
View the Interpretation Document
Response text:
January 10, 2017
Mr. Patrick F. McAtarian
General Manager
Andax Industries LLC
613 West Palmer Street
Saint Marys, KS 66536
Reference No. 16-0173
Dear Mr. McAtarian:
This letter is in response to your October 21, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of a flexible intermediate bulk container (FIBC). Specifically, you indicate that you have a regulated liquid packaged in an “inner package, container, or article” that is then placed in a UN13H4 rated FIBC. You ask if this is an authorized packaging configuration.
The answer is no. With the exception of “large packagings” (see § 171.8), a “bulk package”—such as an FIBC—is defined as a package that is loaded with a hazardous material with no intermediate form of containment. An intermediate form of containment would include an inner packaging, container, or article. Therefore, it is the opinion of this Office that a UN13H4 FIBC is not authorized to be loaded with an inner packaging, container, or article.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
171.8
Regulation Sections
| Section | Subject |
|---|---|
| 171.8 | Definitions and abbreviations |