Interpretation Response #98-0573
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
MAY 1, 1998
Mr. Bobby Roper
Mission Viejo, CA 92691
Dear Mr. Roper
This is in response to your letter requesting clarification of proper descriptions and testing of certain types of intermediate bulk containers (lBC's) to be used in transporting solid materials. I apologize for the delay and regret any inconvenience it may have caused. Your questions have been paraphrased and answered as follows.
Q. Is either 11HZ2 or 21HZ2 intermediate bulk container the appropriate description for an open top collapsible or rigid walled plastic multi-trip bin with a flexible plastic bag liner and a lid?
A. As stated in § 178.707(a)(2), the marking must be completed by replacing the Z with the appropriate capital letter for the material used as the outer packaging. Based on your descriptions, the IBC's in your letter would most likely be described as llHH2 or 21HH2 IBC's.
Q. What is the proper marking and testing for a composite IBC constructed as described above, that is loaded by gravity but discharged by either gravity or vacuum?
A. A composite IBC with a flexible plastic liner that is discharged by vacuum would be considered a UN11HH2 IBC. Discharge by vacuum is not considered discharge under pressure. An IBC discharged by pressure has a potential safety impact of blowing the contents outward in case of rupture. When discharged by vacuum, the failure mode would be the inward collapse of the IBC; no release of hazardous material outside of. the IBC would occur. Testing would be as for any other 11HH2 IBC.
Q. What are the maximum permissible reductions in container dimensions allowed without requiring retesting under the provisions of selective testing? Are shorter or narrower versions of the originally tested and qualified container design permitted as long as it meets the capacity requirement of an IBC?
A. The maximum allowable reduction in IBC exterior dimensions has not been established at this time. All requests for selective testing will be handled on a case by case basis until those limits are defined. However, it is the responsibility of the IBC manufacturer to assure that each IBC is capable of passing all prescribed tests. The manufacturer may conduct tests on the design type, or the manufacturer may receive approval for selective testing from the Office of Hazardous Materials Approvals.
Q. Would a shorter and/or narrower variation container differ from the original tested container design if the width of the container was reduced but the width of the forktine openings remained the same?
A. Based on the limited information presented, the container appears to be acceptable as a variation under selective testing; however, a formal request for approval would need to be submitted. Additionally, in order for the Office of Hazardous Materials Approvals to conduct a thorough evaluation, the request should provide greater design detail.
Q. Should the distance or spacing between and the depth of any external and/or internal bosses or ribs be scaled down proportionately to the overall dimensional reduction in order to be considered the same design?
A. Section 178.801(c)(7fprovides that different intermediate bulk container design type is one that differs from a previously qualified intermediate bulk container design type in structural design, size, material of construction, wall thickness, or manner of construction. If internal or external bosses or ribs are scaled down to meet a smaller size, and it affects the structural design, the IBC must be tested as a new design type. Once again, the Office of Hazardous Materials Approvals must approve the qualification of a container using selective testing.
I hope this answers your questions. If we can be of further assistance, please do not hesitate to contact us.
Edward T. Mazzullo
Director, Office of Hazardous
|§ 178.700||Purpose, scope and definitions|