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Interpretation Response #22-0118

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

Interpretation Response Details

Response Publish Date:

Company Name: Tanner Industries, Inc.

Individual Name: James Klucsarits

Location State: PA Country: US

View the Interpretation Document

Response text:

July 5, 2023

James Klucsarits
Manager of Quality and Regulatory Affairs
Tanner Industries, Inc.
735 Davisville Road
Southampton, PA  18966

Reference No. 22-0118

Dear Mr. Klucsarits:

This letter is in response to your October 27, 2022, email pertaining to the use of intermediate bulk containers (IBCs) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180. In your email, you note that the § 172.101 Hazardous Materials Table lists special provision "IB3" for the proper shipping name "UN2672, Ammonia solutions, relative density between 0.880 and 0.957 at 15 degrees C in water, with more than 10 percent but not more than 35 percent ammonia, 8, PG III." Special provision IB3 authorizes the following IBCs: Metal (31A, 31B, and 31N); Rigid plastics (31H1 and 31H2); Composite (31HZ1 and 31HA2, 31HB2, 31HN2, 31HD2 and 31HH2). You ask whether a specification 31HA1 composite IBC would be authorized for the transportation of "UN2672, Ammonia solutions, relative density between 0.880 and 0.957 at 15 degrees C in water, with more than 10 percent but not more than 35 percent ammonia, 8, PG III."

The answer is yes. Special provision IB3 lists the letter "Z" as a placeholder rather than listing every possible composite IBC type (HA, HB, HC, etc.). Section 172.102(c)(4) states that the letter "Z" in the marking code for composite IBCs must be replaced with a capital code letter designation found in § 178.702(a)(2) to specify the material used for the other packaging. Therefore, a composite 31HA1 IBC would be authorized under special provision IB3 for your material.

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

Sincerely,

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

172.101, 172.102(c)(4), 178.702(a)(2)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.102 Special provisions
178.702 IBC codes