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Interpretation Response #04-0018 ([Eastman Chemical Company] [Ms. Kimberly D. Glover-Brown])

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

Interpretation Response Details

Response Publish Date:

Company Name: Eastman Chemical Company

Individual Name: Ms. Kimberly D. Glover-Brown

Location State: CA Country: US

View the Interpretation Document

Response text:

May, 24, 2004


Ms. Kimberly D. Glover-Brown               Reference No. 04-0018
Eastman Chemical Company
2801 Lynwood Road
Lynwood, CA 90262

Dear Ms. Glover-Brown

This is in response to your January 23, 2004 letter requesting clarification regarding the marking of IBCs under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Specifically, you ask whether a tag showing the retest date affixed near the serial number plate of an IBC would comply with the HMR.

The answer is no.  Section 180.352(e) states that the date of the most recent periodic retest must be marked as provided in § 178.703(b). Section 178.703(b) (2) states, in part, that for each metal IBC, the marking must be included on a metal corrosion resistant-plate.  Therefore, a tag showing the retest date affixed near the serial number plate of an IBC does not conform to the above referenced requirements.

I hope this information is helpful.  If you have additional questions, please do not hesitate to contact this office.



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


Regulation Sections

Section Subject
178.703 Marking of IBCs