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Interpretation Response #12-0056

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

Interpretation Response Details

Response Publish Date: 05-16-2012
Company Name: MD Packaging Solutions LLC    Individual Name: Mr. Dan Dengler
Location state: NJ    Country: US

View the Interpretation Document

Request text:


Response text:

May 16, 2012

Mr. Dan Dengler
MD Packaging Solutions LLC
11 Olde Mill Run
Medford, NJ 08055

Ref. No. 12-0056

Dear Mr. Dengler:

This responds to your February 6, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirement for retest and inspection of intermediate bulk containers (IBCs). Specifically, you ask if you may rely on the leakproofness test and internal visual inspection conducted by the original manufacturer to satisfy the requirement in § 180.352 when repairing an IBC or replacing the inner receptacle of a composite IBC.

Yes. As specified in § 180.352(d)(1), each repaired IBC must be subjected to a leakproofness test as specified in § 178.813, an internal visual inspection and must be marked with the date of the test. The inner receptacle of a composite IBC may be leakproofness tested without the outer packaging provided the test results are not affected (§ 178.813(b)). If you choose to rely on the leakproofness test conducted by the manufacturer of the inner receptacle to satisfy this requirement, you must have evidence to establish that the leakproofness test was performed in accordance with § 178.813 and the internal visual inspection was performed before the IBC is filled and offered for transportation (§ 180.352(g)). The evidence of these tests/inspections should be from the manufacturer of the inner receptacle and identify your company as able to use this certification.

I hope this information is helpful. If you have further questions, please contact this office.



Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division

180.353, 178.813

Regulation Sections

Section Subject
§ 178.813 Leakproofness test