Interpretation Response #00-0149 ([Smurfit-Stone Container Corporation] [Mr. Steven Pfeiffer])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Smurfit-Stone Container Corporation
Individual Name: Mr. Steven Pfeiffer
Location State: IL Country: US
View the Interpretation Document
Response text:
June 2, 2000
Mr. Steven Pfeiffer Ref No. 00-0149
Smurfit-Stone Container Corporation
450 East North Avenue
Carol Stream, IL 60188
Dear Mr. Pfeiffer:
This is in response to your letter dated May 15, 2000, regarding marking of Flexible Intermediate Bulk Containers (FIBCs) or bulk bags made of woven polypropylene under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that one thousand (1,000) of these bags were marked with the incorrect proper shipping name and identification number. You asked whether the methods described below, to cover and correct the wrong markings, would be acceptable in order to make these FIBCs usable:
1) Cover the incorrect marking with a white ink that will completely block out this error, and then reprint the bags with the correct marking; and/or
2) Sew a panel of woven polypropylene fabric over the entire width and length of that side of the four sided container (that would hide the current incorrect print) and then print this "cover panel" with the correct markings. Additionally, you would be willing to block out the marking as suggested above and then sew in this cover panel, if necessary.
Method "I," described above, to correct the markings on these FIBCs appears acceptable. However, as described under method "T," sewing a panel of woven polypropylene fabric over the entire width and length of one side of the four sided container to cover these markings is not acceptable because the added fabric weight would change the structural design, and would be a different intermediate bulk container design type requiring performance testing.
For your information, there is no requirement in HMR to mark an IBC with the proper shipping name of the material being shipped, although it is not prohibited. The identification number must be marked on the FIBC as specified in §172.331.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us
Sincerely,
Delmer F. Billings
Chief, Standards Development
Materials Standards
173.302