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Interpretation Response #18-0107

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

Interpretation Response Details

Response Publish Date: 02-12-2019
Company Name: Elkhart Plastics, Inc    Individual Name: Jason Furrer
Location state: IN    Country: US

View the Interpretation Document

Response text:

December 12, 2018

Jason Furrer
Elkhart Plastics, Inc.
51703 Packard Drive
Middlebury, IN  46540

Reference No. 18-0107

Dear Mr. Furrer:

This letter is in response to your July 19, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of intermediate bulk containers (IBCs).  Specifically, you ask if it is permissible to mark an IBC with leftover decals showing a higher marked weight than the recertified marked weight. 

The answer is no.  Section 178.703 requires the marking of the maximum permissible gross mass in kilograms.  Marking a higher weight would not meet this requirement.  An IBC that is marked to the previously-allowed, higher weight could lead to confusion when filling the package and, possibly, to failure of the package due to overloading.

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


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



Regulation Sections

Section Subject
§ 178.703 Marking of IBCs