Interpretation Response #00-0262 ([Dinda & Associates Incorporated] [Mr. John F. Dinda, Jr])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Dinda & Associates Incorporated
Individual Name: Mr. John F. Dinda, Jr
Location State: PA Country: US
View the Interpretation Document
Response text:
January 9, 2001
Mr. John F. Dinda, Jr. Ref. No. 00-0262
Regulatory Compliance Associate
Dinda & Associates Incorporated
525 Shady Retreat Road
Doylestown, PA 18901
Dear Mr. Dinda:
This responds to your letter regarding the leakproofness testing requirement for an intermediate bulk container (IBC) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you inquire whether an IBC intended to contain liquids that are not discharged under pressure must be leakproofness tested under the periodic retest requirements specified in § 180.352(b)(1). You state that it is your understanding the leakproofness test is required only when the IBC is used for liquids that are loaded or discharged under pressure.
Your understanding of this provision is not correct. Section 180.352(b)(1) states that performance of the leakproofness test is required for each IBC intended to contain solids that are loaded or discharged under pressure and for each IBC intended to contain liquids regardless of the method of discharge. We will consider clarifying this provision in a future rulemaking.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
180.352
Regulation Sections
| Section | Subject |
|---|---|
| 180.352 | Requirements for retest and inspection of IBCs |