Interpretation Response #23-0098
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Consolidated Container Company
Individual Name: William Dworsky
Location State: MN Country: US
View the Interpretation Document
Response text:
April 24, 2024
William Dworsky
President
Consolidated Container Company
109 27th Ave NE
Minneapolis, MN 55418
Reference No. 23-0098
Dear Mr. Dworsky:
This letter is in response to your November 2, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the attachment of "label plates" on repaired and/or remanufactured Intermediate Bulk Containers (IBCs). In your email, you provide a picture of a United Nations (UN) 31HA1 composite IBC with a "label plate" screwed into the steel outer packaging surrounding the plastic inner receptacle. It is your understanding that when a new "label plate" is installed on an IBC, it should be done in a manner that does not affect the integrity of the package.
Your understanding is correct. While the HMR do not specifically state that "label plates"—or any other hazard communication—cannot be screwed into the steel outer packaging surrounding the plastic inner receptacle of a composite IBC, § 173.28(a) states that "before reuse, each packaging must be inspected and may not be reused unless free from incompatible residue, rupture, or other damage which reduces its structural integrity."
Based solely on the picture provided in your email, it is not possible to determine whether the screws in the steel outer packaging have affected the integrity of the composite IBC. However, if you have evidence that the screws have affected the integrity of the composite IBC, this would not be an acceptable method for attaching "label plates." Please note that this letter only addresses the effect that screwing the "label plate" into the outer cage has on the integrity of the composite IBC pictured in your email and does not address the marking requirements associated with this composite IBC.
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
173.28(a)
Regulation Sections
| Section | Subject |
|---|---|
| 173.28 | Reuse, reconditioning and remanufacture of packagings |