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Interpretation Response #13-0037


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

Interpretation Response Details

Response Publish Date: 05-06-2013
Company Name: Public Utilities Commission of Ohio Transportation Department    Individual Name: Mr. Tom Forbes
Location state: OH    Country: US

View the Interpretation Document


Response text:

May 6, 2013

Mr. Tom Forbes
Public Utilities Commission of Ohio
Transportation Department
180 E. Broad St. 4th Floor
Columbus, OH 43215

Ref. No.: 13-0037

Dear Mr. Forbes:

This responds to your February 5, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to intermediate bulk container (IBC) discharge valves.  As an attachment to the letter, you included multiple pictures of an IBC with various views of the bottom discharge valves.  You ask whether the IBC in the pictures meets the general requirements of § 178.704(e); specifically, that the open or closed position of each valve is readily apparent.

The answer is yes.  As required in § 178.704(e), bottom discharge valves must be secured in the closed position and the discharge system suitably protected from damage.  Valves having lever closures must be secured against accidental opening.  The open or closed position of each valve must be readily apparent.  For each IBC containing a liquid, a secondary means of sealing the discharge aperture must also be provided, e.g., by a blank flange or equivalent device.

In the pictures you provided, the position of the discharge valve is readily apparent and conforms to standard operating designs for quarter turn valves (e.g., ball valve, butterfly valve, plug valve, etc.).  When the handle is perpendicular to the pipe axis, the indication is that the valve is closed.  When the handle is in-line with the pipe axis, the indication is that the valve is open.  Therefore, it is the opinion of this Office that the IBC discharge valve included in the pictures complies with the requirement that the open or closed position of each valve must be readily apparent pursuant to § 178.704(e).

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

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


178.704


Regulation Sections

Section Subject
§ 178.704 General IBC standards