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 6.1.1.2.1 of the IMDG Code. Section 6.1.1.2.1 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 6.1.1.2.1 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.
Sincerely
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Safety
171.2
Regulation Sections
| Section | Subject |
|---|---|
| 171.2 | General requirements |