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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 #22-0058

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

Interpretation Response Details

Response Publish Date:

Company Name: Heil Trailer

Individual Name: Mr. Charles Gilson

Location State: KY Country: US

View the Interpretation Document

Response text:

March 20, 2023

Mr. Charles Gilson
Branch Manager
Heil Trailer
3808 Bells Lane
Louisville, KY  40211

Reference No. 22-0058

Dear Mr. Gilson:

This letter is in response to your June 23, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the repair of an intermediate bulk container (IBC). In your letter, you describe two methods to repair a cracked threaded "nipple" used to attach service equipment to an IBC. The first method would involve removing all but one-half inch of the existing threaded "nipple" and welding a 90-degree threaded elbow pipe in its place. The second method would differ only in that the original threaded "nipple" would be removed entirely. You ask whether either proposed method would be considered a repair or constitute a "different IBC design type" as defined in § 178.801(c)(7) of the HMR.

Based on the information and pictures provided in your letter, it is the opinion of this Office that both of your proposed repair methods would constitute a "different IBC design type" and furthermore, the IBC would be required to be retested in accordance with Part 178, Subpart O (Testing of IBCs). Section §178.801(c)(7)(iv) authorizes the replacement of service equipment without it qualifying as a design change. Because the welding of the 90-degree threaded elbow makes a once-removable fitting a permanent part of the packaging, the repair is considered a different IBC design type in accordance with 178.801(c)(7).

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

178.801(c)(7), 178.801(c)(7)(iv)

Regulation Sections

Section Subject
178.801 General requirements