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Interpretation Response #05-0173 ([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:

Aug 29, 2005


Mr. Russell Keith                       Reference No. 05-0173
Wrangler Corporation
68 First Flight Drive
P.O. Box 1970
Auburn, Maine 04211

Dear Mr. Keith:

This is in response to your July 15, 2005 letter requesting further clarification of our letters to you dated June 28, 2005, December 8, 2004, and November 9, 2004 concerning intermediate bulk containers (IBC) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you provide documentation describing your packaging as an “1 1HH2” composite IBC and ask whether an inner receptacle of a compos IBC designed for solids, loaded or discharged by gravity, requires its own closure if the outer receptacle provides closure to the IBC.

As we stated in our previous 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 in your most recent letter and after careful consideration by this Office, it has been determined that your packaging does not meet this standard. Therefore, your packaging may not be marked with the IBC code designation” 11HH2,” and the closure requirements of the inner receptacle of a composite IBC 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