November 27, 2017

 

Jason Furrer

Project Engineer

Elkhart Plastics, Inc.

51703 Packard Drive

Middlebury, IN  46540

 

Reference No. 17-0075

 

Dear Mr. Furrer:

 

This letter is in response to your June 27, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to drop testing requirements for Intermediate Bulk Containers (IBCs).  Specifically, you ask whether the scenario you provide meets the criteria in § 178.810(e) for a failure of the drop test.  You provide pictures showing a broken plastic fitting on a pump mounted to the top neck fill on an IBC and explain that the opening is located at least six inches above the fluid level of the package.  Additionally, you explain that the test lab noted, "minor discharge, but no continued leakage."

 

The criteria for passing the drop test in § 178.810(e) state, "there may be no damage which renders the IBC unsafe to be transported for salvage or for disposable."  Based on the scenario you provided, it is the opinion of this Office that a damaged fitting that creates an opening in the package renders the IBC unsafe to be transported. 

 

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

 

Sincerely,

 

 

 

T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

 

178.810(e)