Interpretation Response #03-0226 ([Dinda & Associates, Inc.] [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, Inc.
Individual Name: Mr. John F. Dinda, Jr.
Location State: GA Country: US
View the Interpretation Document
Response text:
Oct 23, 2003
Mr. John F. Dinda, Jr. Reference No. 03-226
Dinda & Associates, Inc.
6190 Old Still Run Road
Gainesville, GA 30506
Dear Mr. Dinda:
This responds to your letter requesting clarification of the definition for "freight container" under the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). Specifically, you ask if an intermediate bulk container (IBe) meets the definition of a freight container and if so, does the IBC meet the packaging requirements in Special Provision IPl.
The answer is no. An mc does not meet the definition of a freight container. An mc is a rigid or flexible portable packaging designed for mechanical handling. mc's are built to standards specified in 49 CFR Part 178. A freight container is "a reusable container having a volume of 64 cubic feet or more, designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages (in unit form) during transportation." Under the requirements of Special Provision !PI, the IBC must be packed in a closed freight container or a closed transport vehicle. The closed freight container or closed transport vehicle is intended to provide an additional means of containment for the material in the IBC.
I trust this satisfies your inquiry.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
Regulation Sections
| Section | Subject |
|---|---|
| 172.102 | Special provisions |