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Interpretation Response #98-0522 ([DuPont Sourcing] [Mr. Randolph Martin])

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

Interpretation Response Details

Response Publish Date:

Company Name: DuPont Sourcing

Individual Name: Mr. Randolph Martin

Location State: DE Country: US

View the Interpretation Document

Response text:

MAY 7, 1998

 

Mr. Randolph Martin
Hazardous Materials Distribution Consultant
DuPont Sourcing
Wilmington, DE 19898

Dear Mr. Martin:

This is in response to your letter dated November 3, 1997 concerning whether UN liD wooden intermediate bulk containers (nailed plywood boxes with inner woven polypropylene bags) are permitted for reuse if they are refurbished and remarked.

You describe a situation wherein a used UN liD intermediate bulk container (!BC) would be returned to your manufacturing site, inspected for any defects, discarded if it showed signs of undue wear, corrosion, contamination or other damage which might render it unsafe for transportation, refitted with a new polypropylene inner bag and remarked by application of a new date of manufacture. Refurbishing the mc and remarking the date of manufacture in the described manner does not alter the fact that the mc has been used and it is our determination that the prohibition in 49 CFR 173.35(b) against reuse of a wooden mc would still apply.

If you can demonstrate that your procedures achieve a level of safety at least equal to that provided by regulation, you may want to apply for an "exemption under the provisions of 49 CFR 107.105.

I trust this satisfies your inquiry. If we can be of further assistance, please contact us.

Sincerely,

 

Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards

Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings
173.35 Hazardous materials in IBCs