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Interpretation Response #19-0058

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mark Hawk

Location State: TN Country: US

View the Interpretation Document

Response text:

September 12, 2019

Mark B. Hawk
Packaging Management Council Coordinator
8116 Villa Grande Lane
Knoxville, TN  37938

Reference No. 19-0058

Dear Mr. Hawk:

This letter is in response to your May 6, 2019, letters requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the testing requirements for flexible Intermediate Bulk Containers (IBCs).

We have paraphrased and answered your questions as follows:

Q1. You ask what the manufacturer can do to demonstrate that a flexible IBC design type packaging is "capable of withstanding" the vibration test in accordance with § 178.819(a) other than actually performing the vibration test.

A1. The manufacturer must use its discretion to meet this requirement. Determining whether a flexible IBC is capable of withstanding the vibration test may be based on institutional knowledge, prior experience, modeling, or other data. Ultimately, it is the manufacturer's responsibility to ensure the flexible IBC can meet the requirement, which may include performance of the vibration test, or another method.

Q2. You ask whether the methods outlined in § 173.461(a) may be used for other packagings specified in the HMR.

A2. See A1. For a flexible IBC design type packaging, using one of the methods listed in § 173.461(a) may satisfy the requirement.

Q3. You ask where Part 173, Appendix C is referenced in the HMR.

A3. While not specifically cited, Appendix C was included in Part 173 because of the reference to the vibration test required for non-bulk packagings in § 173.24a(a)(5).

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

178.819(a), 173.461(a), 173.24a(a)(5)

Regulation Sections

Section Subject
173.24 General requirements for packagings and packages
173.461 Demonstration of compliance with tests