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Interpretation Response #12-0032 ([MT Associates, L.L.C.] [Mr. E. A. Altemos])

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

Interpretation Response Details

Response Publish Date:

Company Name: MT Associates, L.L.C.

Individual Name: Mr. E. A. Altemos

Location State: VA Country: US

View the Interpretation Document

Response text:

March 15, 2012



Mr. E. A. Altemos
HMT Associates, L.L.C.
603 King Street
Suite 300
Alexandria, VA 22314-3105

Reference No.: 12-0032

Dear Mr. Altemos:

This is in response to your November 9, 2011 letter requesting confirmation, as the Competent Authority of the United States, for the purposes of implementation of the International Maritime Dangerous Goods (IMDG) Code, of your understanding of the meaning of the term "operational equipment" in the context of IMDG Code, and further that no competent authority approval of any operational equipment that may be employed to meet the requirements of that paragraph is necessary under the IMDG Code.

Your understanding is correct. You note that of the IMDG Code allows, as an alternative to purpose-designed and constructed non-pressurized containers for dry bulk conforming to ISO 1496-4:1991 (see, the use as a bulk container of a general purpose freight container conforming to ISO 1496-1:1990, when such freight container is equipped with operational equipment designed to strengthen the end walls and to improve the longitudinal restraint as necessary to comply with the test requirements of ISO 1496-4:1991, provided all other applicable requirements of 6.9.3 are satisfied.

We concur with your understanding that the term "operational equipment" in the context of this provision includes additional structural members, and/or any other materials or means that may be installed that augment the end wall strength as necessary for the freight container with the operational equipment installed to comply with the end wall test requirements of ISO 1496-4:1991. Moreover, it is the responsibility of the person filling and offering the freight container for transport to ensure that this requirement, like all other requirements attached to the use of bulk containers for the transport of solid substances in bulk, is satisfied. Further in this connection, since the need for competent authority approval of such operational equipment is not specifically required under, no approval by this agency of the arrangement employed to satisfy the requirements of that paragraph is necessary.

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



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
171.12 North American Shipments