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Interpretation Response #18-0112


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

Interpretation Response Details

Response Publish Date: 07-01-2019
Company Name: Schuetz Container Systems    Individual Name: Brian Minnich
Location state: NJ    Country: US

View the Interpretation Document


Response text:

July 1, 2019

Brian Minnich
Director Tech Service and Quality
Schuetz Container Systems
200 North Aspen Hill Road
North Branch, NJ 08876

Reference No. 18-0112

Dear Mr. Minnich:

This letter is in response to your August 2, 2018, email and subsequent phone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for marking an Intermediate Bulk Container (IBC). Specifically, you ask whether the IBC may be marked with a stacking test load at a lesser level than the successful test result or a capacity lower than the rated capacity the IBC was designed to. For example, you present a scenario where a composite IBC successfully completed the test at 3855 kg but is marked 3700 kg, and the rated capacity of the packaging is 2031 L but is marked 2020 L. You ask if this conforms to the marking requirements in § 178.703.

The answer is no. An IBC may not be marked at a lower weight than the stacking test load at which it was successfully tested. In accordance with § 178.703(a)(1)(vii), IBCs must be marked with "the stacking test load in kilograms (kg)." The stacking test load marking is associated with the additional marking requirements for the IBC stack symbol found in § 178.703(b)(7). Specifically, in § 178.703(b)(7)(iv), the maximum permitted stacking load in kilograms must be displayed. The mass marked above the symbol must not exceed the load imposed during the design test, as indicated in § 178.703(a)(1)(vii), divided by 1.8. Further, an IBC must be marked with the rated capacity it was designed to in liters of water at 20 °C (68 °F), as prescribed in § 178.703(b)(1)(i).

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

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
178.703, 178.703(a)(1)(vii), 178.703(b)(7), 178.703(b)(7)(iv), 178.703(b)(1)(i)


Regulation Sections

Section Subject
§ 178.703 Marking of IBCs