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Interpretation Response #05-0040 ([Bonar Plastics] [Mr. Gustavo Cuevas])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bonar Plastics

Individual Name: Mr. Gustavo Cuevas

Location State: IL Country: US

View the Interpretation Document

Response text:

May 5, 2005

 

Mr. Gustavo Cuevas                      Reference No. 05-0040

Plant Manager

Bonar Plastics

1005 Atlantic Drive

West Chicago, IL 60185

Dear Mr. Cuevas:

This is in response to your letter dated February 14, 2005 requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180) applicable to testing and marking of Intermediate Bulk Containers (IBCs). Specifically, you state that your company manufactures IBCs certified for use with materials of 1.2 specific gravity that have recently been re-certified for use with materials of 1.5 specific gravity without undergoing a design change. You ask whether your IBCs currently in use may be re marked for use with materials of 1.5 specific gravity without being re-tested.

As specified by § 178.80 1, it is the responsibility of the IBC manufacturer to assure that each IBC is capable of passing the prescribed tests in Subpart 0 of the HMR. In addition, the application of the certification mark by the manufacturer constitutes certification that the IBC design type passed the prescribed tests in Subpart 0 of the HMR, including the periodic design requalification test. Provided your IBCs currently in use meet the testing and certification requirements as specified in the HMR, you may re mark them to indicate that they are authorized for use with materials of 1.5 specific gravity without retesting.

I hope this information is helpful.

Sincerely,

 

Susan Gorsky

Senior Transportation Regulations Specialist

Office of Hazardous Materials Standards

173.24a(b)(3)

Regulation Sections

Section Subject
173.24a Additional general requirements for non-bulk packagings and packages