USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #05-0057 ([ICI Paint; Exports & Licensing] [Ms. Julie Naus])

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

Interpretation Response Details

Response Publish Date:

Company Name: ICI Paint; Exports & Licensing

Individual Name: Ms. Julie Naus

Location State: OH Country: US

View the Interpretation Document

Response text:

May 4, 2005


Ms. Julie Naus                       Reference No. 05-0058
International Traffic/Export Specialist
ICI Paint; Exports & Licensing
16651 Sprague Road
Strongsville, Ohio 44136

Dear Ms. Naus:

This responds to your February 15, 2005 letter requesting clarification concerning the use of a 1 A2 steel drum containing a plastic insert with an inner receptacle under the International Maritime Dangerous Goods (IMDG) Code. Specifically you ask if this packaging configuration would be authorized under section of the IMDG Code. Section allows for the use of alternative packaging specifications under certain conditions including an authorization by the competent authority.

In our opinion, a removable head steel drum containing a plastic insert with an inner receptacle may be performance tested as a UN 1A2 steel drum. Once this configuration is successfully tested, in the form intended for transport, to the UN 1A2 specification it may be considered a single packaging. Therefore, section is not applicable since UN 1A2 steel drums are authorized under 6.1.4 of the IMDG Code.

I hope this information is helpful. Please contact us if you require additional assistance.



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


Regulation Sections

Section Subject
171.2 General requirements