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Interpretation Response #00-0210 ([Research Products, Inc.of Alabama] [Mr. Doug Martin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Research Products, Inc.of Alabama

Individual Name: Mr. Doug Martin

Location State: AL Country: US

View the Interpretation Document

Response text:

January 2, 2001


Mr. Doug Martin                              Ref. No. 00-0210
Vice President
Research Products, Inc.,
of Alabama
P.O. Box 705
Theodore, AL 36590

Dear Mr. Martin:
This is in response to your letter inquiring whether the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) permit the contents of an intermediate bulk container (IBC) to be discharged into a permanent storage tank while the IBC remains on a motor vehicle.  You state that the IBC contained a Class 8 (corrosive) liquid.

The answer is no. The HMR do not permit IBC’s to be unloaded prior to removal from a motor vehicle.  Section 177.834(h) authorizes this practice for cargo tanks and IM portable tanks only, if certain conditions are met.  We issued several exemptions that authorize IBCs to be unloaded without removing them from the vehicle.  The procedures for submitting an application for exemption are contained in 49 CFR 107.105.

Our Office of Hazardous Materials Exemptions and Approvals (OHMEA) plans to consolidate the current exemptions that provide relief for IBCs from the unloading requirements in § 177.834(h) into one standardized exemption.  On June 12, 2000, OHMEA published a notice in the Federal Register that solicited comments on the safety measures that should apply during the unloading operations (Docket No. RSPA-2000­6827; 65 FR 36882).  A copy of the notice is enclosed for your information.  Comments received in response to this notice are available for review by the accessing DMS website at   “”

I hope this satisfies your request.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
177.834 General requirements