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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 #24-0017

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

Interpretation Response Details

Response Publish Date:

Company Name: Champion X

Individual Name: Melanie Barker

Location State: TX Country: US

View the Interpretation Document

Response text:

April 24, 2024

Melanie Barker
Regulatory Specialist
Champion X
11177 S. Stadium Drive
Sugar Land, TX  77478

Reference No. 24-0017

Dear Ms. Barker:

This letter is in response to your March 7, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding vessel transportation of "UN3286, Flammable liquid, toxic, corrosive, n.o.s., 3 (6.1, 8), PG II" in composite intermediate bulk containers (IBCs). You ask whether the IBCs authorized in the HMR for a commodity transported using this hazardous materials description satisfies the International Maritime Dangerous Goods (IMDG) Code requirement for a competent authority approval (CAA), or if a CAA letter is still required to transport it internationally via vessel. More specifically, you ask whether a CAA (letter) is required to transport a 31HA1 composite IBC for vessel transportation of this material.

The answer is no. Your understanding is correct that special provision IB2—which is assigned to the UN3286 Packing Group (PG) II entry in the § 172.101 Hazardous Materials Table—authorizes composite (31HZ1) IBCs for transportation, including for vessel transportation. Further, the HMR authorizes the use of composite IBCs for UN3286 materials, provided the packaging meets the conditions and limitations in § 173.243(d).

Note also that a CAA, as defined in § 105.5, is an approval by the competent authority that is required under an international standard, and that a specific regulation in the HMR may be considered a CAA if it satisfies the requirement of an international standard—see, for example, section of the IMDG Code. Therefore, the authorization in the HMR for use of composite IBCs for transportation of a UN3286 PG II material serves as a U.S. CAA.

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

105.5, 172.101, 173.243(d)

Regulation Sections

Section Subject
105.5 Definitions
172.101 Purpose and use of hazardous materials table
173.243 Bulk packaging for certain high hazard liquids and dual hazard materials which pose a moderate hazard