Interpretation Response #02-0195 ([INDSPEC Chemical Corporation] [Vicki H. Weightnian])

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

Interpretation Response Details

Response Publish Date: 10/03/2002

Company Name: INDSPEC Chemical Corporation

Individual Name: Vicki H. Weightnian

Location State: PA Country: US

View the Interpretation Document

Response text:

Oct 3, 2002

Ms. Vicki H. Weightnian                   Reference No. 02-0195

INDSPEC Chemical Corporation

1010 William Pitt Way

Pittsburgh, PA 15238

Dear Ms. Weightman:

This is in response to your letter requesting clarification on the requirements for IBCs under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  I apologize for the delay in answering and hope it has not caused you any inconvenience.

Your questions are paraphrased and answered below:

Q1. Does a successful vibration test indicate a flexible IBC is sift proof?

A1. A fexible IBC must be capable of withstanding the vibration test without rupture or leakage.  If there is no rupture and or release of material, the IBC is considered sift proof.

Q2. What is the definition of water resistant?

A2. The HMR, at § 171.8, define "water resistant" as "having a degree of resistance to permeability by and damage caused by water in liquid form."

Q3. Is a coated flexible IBC considered water resistant?

A3. The purpose of the coating is to make the IBC "water resistant" or "waterproof." The coating must resist the penetration of water in order to meet the HMR standard.

Q4. Is a 13H2 flexible IBC considered sift proof and water resistant under the current HMR?

A4. The marking "13H2" on a flexible IBC indicates that the IBC is made of woven plastic and coated. It is the opinion of this office that the IBC meets the requirements for "sift-proof and water-resistant" in § 178.704 if the IBC resists the penetration of water and is capable of passing the vibration test without rupture or leakage.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

178.710

Regulation Sections