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Interpretation Response #04-0024 ([Wrangler Corporation] [Mr. Russell Keith])

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

Interpretation Response Details

Response Publish Date:

Company Name: Wrangler Corporation

Individual Name: Mr. Russell Keith

Location State: ME Country: US

View the Interpretation Document

Response text:

Nov 9, 2004


Mr. Russell Keith                 Reference No. 04-0024
Wrangler Corporation
65 First Flight Drive
Auburn, ME 04211

Dear Mr. Keith:

This is in response to your letter regarding the designation of Intermediate Bulk Containers (IBC) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on the designation of your packaging.

According to your letter, your packaging is constructed with a flexible plastic inner liner that is bonded to a rigid fiberboard. The inner liner terminates after being hemmed over the top edge of the fiberboard. The outer plastic body is bonded to the rigid fiberboard and inner lining, forming an integral unit. The outer packaging covers the bottom, sidewalls, and top of the container. Two flaps on adjacent top edges are used for closure. Tie straps are inserted through the lace holes provided in the closure flap and tied in a knot to secure the cover flaps. The container is completed w no separate loose articles, and is filled, stored, shipped and emptied as a unit. You also submitted a sample of your packaging to this Office for further examination. Your letter request; whether your packaging as described above can be marked with the designation, “11HH2.”

The answer is no. Based on the description of your packaging and subsequent assessment of the sample you submitted, your packaging does not conform to the specification for a rigid plastic IBC, and, thus, may not be marked with the IBC code designation “1 1HH2.” As specified in § 178.706(b): rigid plastic IBCs consist of a rigid plastic body, which may have structural equipment, together with appropriate service equipment. The woven plastic outer sheet of your packaging acquires its rigidity only when bonded to a rigid fiberboard. It is our opinion that a flexible plastic material bonded to fiberboard is not a rigid plastic material as addressed in § 178.706. Also, the woven plastic outer sheet of your packaging which covers the bottom, sidewalls and top of the container as described in your letter does not exhibit strength relative to its capacity and the service it is required to perform. In conclusion, it does not appear that your packaging conforms to the UN
11HH2 specification or other IBC specifications. If you believe your packaging provides a level of safety equivalent to the UN 11HH2 specification, or another IBC specification, and you can demo this, you may wish to apply for an exemption for your packaging. The procedures for applying for an exemption are found in § 107.105 of the

I hope this information is helpful.

Edward T. Mazzullo
Director, Office of Hazardous
Material Standards


Regulation Sections

Section Subject
178.707 Standards for composite IBCs