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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #19-0005

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

Interpretation Response Details

Response Publish Date:

Company Name: Baker Petrolite, LLC

Individual Name: David T. Hird

Location State: TX Country: US

View the Interpretation Document

Response text:

July 10, 2019

Mr. David T. Hird
North America Transportation Manager:
Health, Safety & Environment
Baker Petrolite, LLC
2001 Rankin Road
Houston, TX 77073

Reference No. 19-0005

Dear Mr. Hird:

This is in response to your December 23, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to safety control measures in Section 7 of the Department of Transportation Special Permit (DOT-SP) 12412. Specifically, you ask two questions concerning how this special permit applies to intermediate bulk containers (IBCs). We have paraphrased your questions and answered them in the order presented.

Q1. You ask whether the safety control measures in DOT-SP 12412 apply to all IBCs.

A1. The answer is no. The safety control measures prescribed in DOT-SP 12412 apply only to the IBC specifications listed in paragraph 7.a of that special permit: UN 31A, UN 31B, UN 31N, UN 31H1, UN 31H2, and UN 31HZ1.

Q2. You ask whether an IBC (e.g., a UN 31A) that meets the bottom outlet requirements in § 178.275(d)(3), as specified in DOT-SP 12412, is also subject to the remaining bottom outlet requirements stipulated in § 178.275(d).

A2. The answer is no. IBCs conforming with DOT-SP 12412 are not subject to the remaining requirements prescribed in § 178.275(d) because these apply to portable tanks with bottom outlets only.

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


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

Regulation Sections

Section Subject
178.275 Specification for UN Portable Tanks intended for the transportation of liquid and solid hazardous materials