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Interpretation Response #05-0112 ([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:

JUN 8, 2005


Mr.Russell Keith                       Ref. No.: 05-0112
Wrangler Corporation
68 First Flight Drive
P.O. Box 1970
Auburn, Maine 04211

Dear Mr. Keith:

This is in response to your April 29, 2005 letter requesting further clarification of our letter to you dated November 9, 2004 concerning intermediate bulk containers (IBC) under the Hazardous Materials Regulations ~; 49 CFFt Parts 171-180). Specifically, you ask about requirements for closure of the inner receptacle of a composite mc.

As we stated in our November 9, 2004 letter, as specified in § 178.707, a composite IBC is an IBC that consists of a rigid outer packaging and is designed to bear the entire stacking load. Based on the description of your packaging and subsequent assessment of a sample you submitted, your packaging does not meet the requirement for a rigid outer packaging. Therefore, your packaging may not be marked with the IBC code designation "11HH2," and the closure requirements of the inner receptacle of a composite IBe do not apply to your packaging.

If you believe your packaging provides a level of safety equivalent to the United Nations (UN) 11HH2 specification, or another IBC specification, and can demonstrate this, you may wish to apply for an exemption for your packaging.

I hope this information is helpful.



Susan Gorsky
Acting Director
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
178.707 Standards for composite IBCs