Interpretation Response #06-0054 ([Scranton Cooperage, Inc.] [Mr. Eric Spatt])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Scranton Cooperage, Inc.
Individual Name: Mr. Eric Spatt
Location State: PA Country: US
View the Interpretation Document
Response text:
Apr 7, 2006
Mr. Eric Spatt Reference No. 06-0054
Scranton Cooperage, Inc.
1264 Mid Valley Drive
Jessup, PA 18434
Dear Mr. Spatt:
This responds to your letter concerning the markings on intermediate bulk containers (IBCs) required by § 180.352 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask what is meant by “durably mark the IBC near the manufacturer’s UN design type marking.”
Section 180.352 requires the person performing routine maintenance on an IBC to durably mark the JBC with the country in which the routine maintenance is carried out and the name or authorized symbol of the party performing the routine maintenance. “Durable” generally means “able to exist for a long time without significant deterioration.” It is our opinion that the required markings should remain on the IBC and be clearly legible until the next scheduled retest arid inspection.
I trust this satisfies your request.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
180.352
Regulation Sections
| Section | Subject |
|---|---|
| 180.352 | Requirements for retest and inspection of IBCs |