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Interpretation Response #98-0606 ([HMT Associates, L.L.C.] [Gordon Rousseau])

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

Interpretation Response Details

Response Publish Date:

Company Name: HMT Associates, L.L.C.

Individual Name: Gordon Rousseau

Location State: DC Country: US

View the Interpretation Document

Response text:

SEP 3, 1998


Mr. Gordon Rousseau
HMT Associates, L.L.C.
1850 K Street NW
Suite 200
Washington, DC 20006

Dear Mr. Rousseau:

This is in response to your letter of September 3, 1998, requesting clarification on the marking requirements for intermediate bulk containers (IBCs) under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180) Specifically you ask if an inner receptacle for an IBC may be m ked with three different standards (e.g., 31HA1, 31HG1 and 31HH1) to identify it as having been tested and suitable for use with anyone of the three outer casings (i.e., metal, fiberboard or plastic).

The answer is yes. There is no prohibition in the HMR against placing multiple markings on an receptacle of an IBC to show that it has been tested to different standards.

I hope this information is helpful.



Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards


Regulation Sections

Section Subject
178.703 Marking of IBCs