Interpretation Response #06-0268
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Jan 25, 2007
Mr. Craig Heinze Reference No. 06-0268
Bonar Plastics, Inc.
1005 Atlantic Drive
West Chicago, IL 60185
Dear Mr. Heinze
This is in response to your November 17, 2006 letter regarding testing requirements for IBC’s under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You describe the IBC as a plastic bottle with two different sized openings in the bottle top, nine inches and two inches. You provided pictures of the IBC with an arrangement of eight different possible fittings. You ask if the IBC may utilize a single certification number, provided it is successfully tested with each of the eight different fittings.
Section 178.801(d) requires design qualification testing at the start of production of each new or different IBC design type. Section 178.801 defines a “different IBC design type” as one that differs from a previously qualified IBC design type in structural de size, material of construction or wall thickness, but does not include a packaging that differs in service equipment. Section 178.700(c)(2) defines service equipment to mean filling and discharge, pressure relief, safety, heating and heat-insulating devices and measuring instruments. An IBC may be certified as a single design type provided: (1) the fittings meet the definition of service equipment; and (2) the IBC successfully passes the design
qualification testing requirements with service equipment representative of each of the fittings described in your letter. Note that, a description of the design type, including the representative service equipment used for testing the IBC, is required to be documented under the recordkeeping requirements in § 178.801(1).
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
|§ 178.801||General requirements|