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Interpretation Response #05-0299 ([Akzo Nobel Chemicals] [Mr. Mark A Connolly])

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

Interpretation Response Details

Response Publish Date:

Company Name: Akzo Nobel Chemicals

Individual Name: Mr. Mark A Connolly

Location State: IL Country: US

View the Interpretation Document

Response text:

Feb 3, 2006

Mr. Mark A Connolly                           Reference No. 05-0299

Manager Transportation Regulations

    and Security

Akzo Nobel Chemicals

300 South Riverside Plaza

Chicago, IL 60606-6697

Dear Mr. Connolly:

This is in response to your October 7, 2005 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you seek clarification regarding the specification plate markings for initial test and inspection of UN31A metal intermediate bulk containers (IBCs).

According to your letter, your company recently purchased new UN31A IBCs for the transportation of organic peroxides. These IBCs contain all of the information required by § 178.703(a) on a specification plate. Except for the month and year of the last leakproofness test and the month and year of last inspection, the IBCs are marked with the additional information required by § 178.703(b)(2).

In accordance with § 178.8 13, a leakproofness test must be conducted for the qualification of all IBC design types and on all production units intended to contain liquids or solids loaded or discharged under pressure. Each IBC must also have an external visual inspection initially after production and every 2.5 years starting from the date of manufacture. The month and year of the leakproofhess test and last inspection must be man d on each IBC as required by § 178.703(b) before an IBC may be filled and offered for transportation.

The person who certifies an IBC must keep records of design qualification tests in accordance with § 178.801(1).

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


John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

178.703, 178.801, 180.350

Regulation Sections

Section Subject
178.703 Marking of IBCs
178.801 General requirements
180.350 Applicability and definitions