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Interpretation Response #06-0245 ([Reagent Chemical & Research, Inc.] [Mr. Robert Dritschel])

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

Interpretation Response Details

Response Publish Date:

Company Name: Reagent Chemical & Research, Inc.

Individual Name: Mr. Robert Dritschel

Location State: NJ Country: US

View the Interpretation Document

Response text:

Jan 10, 2007


Mr. Robert Dritschel                 Reference No. 06-0245
Site Manager
Reagent Chemical & Research, Inc.
124 River Road
Middlesex, NJ 08846

Dear Mr. Dritschel:

This is in response to your letters of October 23 and 26, 2006, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a flexible intermediate bulk container (FIBC) detailed in your letter and attached photographs is properly labeled and placarded.

Base on information contained in your letter and photographs, your FIBCs qualify for the exception in § 172.514(c)(4) and are not subject to the duplicate labeling requirements in § 172.406(e). Section 172.514(c)(4) provides an exception from placarding requirements for IBCs provided they are labeled in accordance with Subpart E of Part 172. Furthermore, § 172.406(e) specifies instances in which duplicate labeling is required by the HMR. However, you should also be aware of the label specification requirements contained in § 172.407 concerning the appropriate size and design of labels.

In addition, while you appear to be in compliance with the labeling and placarding requirements detailed in your letter and photographs, it is important to note that these are not the only requirements in determining full compliance with the HMR. Please be aware that the UN (or NA) number must be displayed on a bulk packaging in accordance with the marking requirements in § 172.302 and 172.332 through the use of an orange panel or a white square on-point configuration.

I hope this satisfies your request.



Charles E. Betts
Senior Transportation Specialist
Office of Hazardous Materials Standards

172.406(e), 172.514(c)(4)
172.302, 172.332

Regulation Sections

Section Subject
172.302 General marking requirements for bulk packagings.
172.332 Identification number markings
172.406 Placement of labels
172.514 Bulk packagings