Interpretation Response #08-0175 ([GEO Specialty Chemicals] [Mr. Matt Beasley])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: GEO Specialty Chemicals
Individual Name: Mr. Matt Beasley
Location State: GA Country: US
View the Interpretation Document
Response text:
July 24, 2008
Mr. Matt Beasley
GEO Specialty Chemicals
701 Wissahickon Avenue
Cedartown, GA 30125
Ref. No. 08-0175
Dear Mr. Kehrli:
This responds to your July 2, 2008 letter requesting clarification of the placarding and labeling requirements for intermediate bulk containers (IBCs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the exception from placarding provided in § 172.514(c) would allow the use of labels, rather than placards, on 175 gallon IBCs containing corrosive materials.
In accordance with § 172.514, except as provided in paragraph (c), each person who offers for transportation a bulk packaging that contains a hazardous material must affix the placards specified for the material in §§ 172.504 and 172.505. The bulk packaging placarding exception for IBCs provided in § 172.514(c)(4) excepts an IBC from placarding if it is labeled in accordance with Part 172, Subpart E of the HMR. Therefore, the HMR allow the use of CORROSIVE labels on 175 gallon IBCs containing corrosive materials.
You should also note that an IBC must be marked with an identification number as specified in §§ 172.332 and 172.336. The authorized sizes and options for display of acceptable identification number markings are prescribed in § 172.332. The options include an orange panel, a placard, or a white square-on-point configuration. For an IBC contained in or on a transport vehicle or freight container, if the identification number marking on the IBC is not visible, the transport vehicle or freight container must be marked as required by § 172.332.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
Susan Gorsky
Acting Chief, Standards Development
Office of Hazardous Materials Standards
172.514, 172.332, 172.336
Regulation Sections
| Section | Subject |
|---|---|
| 172.332 | Identification number markings |
| 172.514 | Bulk packagings |