Interpretation Response #03-0081 ([NOVA Chemicals Inc.] [Mi. Dean Pettibon])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: NOVA Chemicals Inc.
Individual Name: Mi. Dean Pettibon
Location State: PA Country: US
View the Interpretation Document
Response text:
Apr 22,2003
Mi. Dean Pettibon Reference No. 03-0081
Commodity Manager
NOVA Chemicals Inc.
1550 Coraopolis Heights Road
Moon Township, PA 15108
Dear Mi. Pettibon:
This is in response to your March 11, 2003 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to testing for Intermediate Bulk Containers (IBCs). Specifically, you ask if performance testing is required for IBC packaging under Special Provision IP7 of the Hazardous Material Table (HMT) for “Polymeric beads, Expandable.”
The answer is no. Special IBC Packing Provision IP7 for UN identification number UN2211, “Polymer beads, involving flammable vapor” specifies that IBCs are not required to meet the IBC performance tests specified in Part 178, Subpart N of the HMR.
This Special Provision was added as part of a June 21, 2001 Final Rule, Harmonization With the United Nations Recommendations, International Maritime Dangerous Goods Code, and International Civil Aviation Organization’s Technical Instructions, under Docket No. HM-215D. A copy of this Final Rule is available on our website at http://hazmat.dot.gov under the Rules and Regulations icon, in the Rulemakings and Federal Register Notices. The Final Rule amended the HMR to maintain alignment with international standards and included miscellaneous changes in the HMT, List of Marine Pollutants, and the provisions for IBCs.
I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.102
Regulation Sections
Section | Subject |
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172.102 | Special provisions |