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Interpretation Response #16-0173 ([Andax Industries LLC.] [Mr. Patrick McAtarian])

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

Interpretation Response Details

Response Publish Date:

Company Name: Andax Industries LLC.

Individual Name: Mr. Patrick McAtarian

Location State: KS Country: US

View the Interpretation Document

Response text:

January 10, 2017

Mr. Patrick F. McAtarian
General Manager
Andax Industries LLC
613 West Palmer Street
Saint Marys, KS  66536

Reference No. 16-0173

Dear Mr. McAtarian:

This letter is in response to your October 21, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of a flexible intermediate bulk container (FIBC).  Specifically, you indicate that you have a regulated liquid packaged in an “inner package, container, or article” that is then placed in a UN13H4 rated FIBC.  You ask if this is an authorized packaging configuration.

The answer is no.  With the exception of “large packagings” (see § 171.8), a “bulk package”—such as an FIBC—is defined as a package that is loaded with a hazardous material with no intermediate form of containment.  An intermediate form of containment would include an inner packaging, container, or article.  Therefore, it is the opinion of this Office that a UN13H4 FIBC is not authorized to be loaded with an inner packaging, container, or article.  

I hope this information is helpful.  Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
171.8 Definitions and abbreviations