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Section §180.352: Requirements for retest and inspection of IBCs

Below are the available interpretations and guidance for the given section. To return to the list of parts, use the Parts link above. If you do not see any guidance or interpretation information below, that means there is none available for the given part/section. Return to the search page to browse additional regulations sections.

PHMSA has published several Frequently Asked Questions (FAQ) documents on regulatory topics. Please review our FAQ documents below:

Additionally PHMSA has Hazardous Materials FAQs based on letters of interpretation on the following topics:

This section of the website provides the ability to find regulations information including regulations parts, content of sections, and interpretations for regulations sections. Below is a list of parts, identified by the part number and subject. To browse sections by part, click on the subject link below. You will be taken to the eCFR website to view sections for a part.

A written regulatory interpretation, response to a question, or an opinion concerning a pipeline safety issue may be obtained by submitting a written request to the Office of Pipeline Safety (PHP–30), PHMSA, U.S. Department of Transportation, 1200 New Jersey Avenue SE., Washington, DC 20590–0001 or at the email address: In addition to email address, the requestor must include his or her return address and should also include a daytime telephone number. Requests should be submitted at least 120 days before the time the requestor needs a response.

Note: electronic submission is provided as alternative to the 49 CFR Part 190.11(b) mail-in requirement.

The regulations text of the section can be found on the eCFR website. To view the regulations text, use the link below. For assistance, please send an email to

View section 180.352 on the ECFR website

Interpretation Responses

Ref ID Date Company Name Individual Name Response Document
CHI-13-001 Lawrence W. Bierlein View
CHI-14-001 Reusable Industrial Packaging Association Paul W. Rankin View
06-0054 Scranton Cooperage, Inc. Mr. Eric Spatt View
00-0262 Dinda & Associates Incorporated Mr. John F. Dinda, Jr View
11-0191 Carus Chemical Company Chithambarathanu G. Pillai, Ph.D. View
10-0266 Maxum West Mr. Brian Biancavilla View
12-0056 MD Packaging Solutions LLC Mr. Dan Dengler View
10-0060 URS Corporation Ms. Erin Jarman View
15-0047 Columbus Chemical Industries Ms. Laura Buholca View
08-0286 Packaging Applications for Dangerous Goods, LLC Mr. David Gluntz View
12-0056R Reusable Industrial Packaging Association, MD Packaging Solutions LLC & Lawrence W. Bierlein, Esq. Mr. Paul W. Rankin, Mr. Dan Dengler & Mr. Lawrence W. Bierlein, Esq. View
10-0056 Custom Metalcraft, Inc. Mr. Clark Holden View