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Interpretation Response #07-0098 ([Brenntag Southeast, Inc.] [Mr. Bruce Biehl])

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

Interpretation Response Details

Response Publish Date:

Company Name: Brenntag Southeast, Inc.

Individual Name: Mr. Bruce Biehl

Location State: NC Country: US

View the Interpretation Document

Response text:

July 9, 2007

Mr. Bruce Biehl                                         Reference No. 07-0098

Director of Regulatory Affairs

Brenntag Southeast, Inc.

2000 E. Pettigrew Street

Durham, NC 27703

Dear Mr. Biehl:

This responds to your letter requesting clarification of the IBC marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the portable tank marking requirements in § 172.326 also apply to an IBC. In addition, you ask for confirmation that if the identification number markings required by § 172.302(a) on an IBC are not visible, the transport vehicle or freight container must be marked as required by § 172.332 on each side and each end with the identification number specified in the § 172.101 Table.

The marking requirements specified in § 172.326 apply only to portable tanks. In addition, your understanding of the identification number marking requirements for an IBC in § 172.33 1 and 172.332 is also correct.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.326, 172.331

Regulation Sections

Section Subject
172.326 Portable tanks
172.331 Bulk packagings other than portable tanks, cargo tanks, tank cars and multi-unit tank car tanks