Interpretation Response #00-0158
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
September 21, 2000
Mr. John H. Lapoint Ref. No. 00-0158
P.O. Box 1667
48 Commercial Street
Lewiston, Maine 04241-1667
Dear Mr. Lapoint:
This responds to your letter regarding the proper description and marking of a composite intermediate bulk container (IBC) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter you describe a plastic inner receptacle supported by a rigid outer packaging, known as a "Waste Wrangler", that you believe meets the definition of a 11HH2 composite IBC.
Under the HMR, a composite IBC is an intermediate bulk container which consists of a rigid outer packaging enclosing a plastic inner receptacle together with any service or other structural equipment. See §178.707(b)(1). We agree that the packaging described in your letter would meet the definition of a composite IBC if it is filled, stored, transported, and emptied as a unit. If it satisfies this criteria, the appropriate marking code would be 11HH2. See §178.707(a).
I trust this satisfies your request. If you have further questions, please do not hesitate to contact this office.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 178.801||General requirements|