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Interpretation Response #23-0092

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

Interpretation Response Details

Response Publish Date:

Company Name: Encore Container

Individual Name: Chas Key

Location State: SC Country: US

View the Interpretation Document

Response text:

March 21, 2024

Mr. Chas Key
Encore Container
7021 Augusta Road
Greenville, SC  29605

Reference No. 23-0092

Dear Mr. Key:

This letter is in response to your July 28, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the testing of a UN31HA1 composite intermediate bulk container (IBC) intended to contain liquids. Specifically, you ask whether the HMR require that a composite IBC be vented so that the internal and external pressures reach equilibrium after concluding a drop test performed in accordance with § 178.810.

The answer is no. As noted in your email, the HMR—as provided in § 178.603(f)(1)—states that a non-bulk packaging containing liquids is considered to successfully pass the drop test for each sample tested if each packaging does not leak when equilibrium has been reached between the internal and external pressures, except for inner packagings of combination packagings when it is not necessary that the pressures be equalized. However, for composite IBCs intended to contain liquids, the IBC must be filled to not less than 98 percent of their maximum capacity, and the pressure relief devices must be removed and their apertures plugged or rendered inoperative. See § 178.810(b)(1). Furthermore, for all IBC design types—including composite IBCs—the criteria for passing the drop test means: (1) there may be no damage which renders the IBC unsafe to be transported for salvage or for disposal, and no loss of contents; (2) the IBC shall be capable of being lifted by an appropriate means until clear of the floor for five minutes; and (3) a slight discharge from a closure upon impact is not considered to be a failure of the IBC provided that no further leakage occurs. See § 178.810(e). As such, there is no specific requirement to vent a composite IBC after concluding a drop test so that the internal and external pressures reach equilibrium. While it is not a requirement, allowing an IBC to reach pressure equilibrium is permissible.

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

Sincerely,

Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

178.810, 178.603(f)(1), § 178.810(b)(1), 178.810(e)

Regulation Sections