ChemTreat, Inc. — Hazardous Materials Safety Interpretation

Page 1• J.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Research and peciai Program: dministratio: JUN 1 0 2002 Mr. John Mardigian Ref. No. 01-0286 Chem Treat, Inc. 10040 Lickinghole Road Ashland, VA 23005 Dear Mr. Mardigian: This responds to your letter regarding marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for Intermediate Bulk Containers (IBCs) having capacities of 75, 275, 300, or 400 gallons. Specifically, you asked if marking the proper shipping name of a hazardous material in 50 mm (2.0 inches) letters on an IBC, by stenciling, is required; or, would such information already included on a product label affixed to an IBC satisfy the marking requirements. In a subsequent telephone conversation, with a member of my staff, you said that the 75 gallon capacity container was a non-bulk packaging, not an IBC. An IBC must be marked with an identification number as specified in §§ 172.302, 172.331 and 172.332. The size of an identification number marking on an IBC must have a width of at least 4.0 mm (0.16 inch) and, with a capacity of less than 3,785 L (1,000 gallons), a height of at least 25 mm (one inch). An identification number marking for an IBC with a capacity of more than 3,785 L (1,000 gallons) must be at least 50 mm (2.0 inches) in height. For an IBC contained in or on a transport vehicle or freight container, if the identification number marking on the IBC is not visible, the transport vehicle or freight container must be marked as required by § 172.332. contuation. A produc be mayed on used to get lan lanie to suite e are ing display on an IBC. : 332 112. 010286#

Page 2The marking requirements for non-bulk packagings (i.e., having a capacity of less than 119 gallons) are found in § 172.301. The 75 gallon capacity container is a non-bulk packaging, as defined in § 171.8, and must be marked with the proper shipping name and identification number. A product label may be used to satisfy the marking reguirements on a non-bulk packaging, such as the 75 gallon capacity container, as long as it meets the general marking requirements in §§ 172.301 and 172.304. I hope this information is helpful. If we can be of further assistance, please contact us. Sincerely, Delm 765 allo Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3. 11/02/2001 15:42 FAX Engrum @001/001 §112.337 10040 Lickinghole Road Astland, VA 23005 abelino "|- 028g facsimile transmittal To: Ben Fax: From: John Mardigian Date: Novembor 2, 2001 Re: Pages: CC: g Urgent • For Review • Please Comment X Please Reply O Please Recycle • • • • • What are the proper labeling requirements for shipping IBCs (75-gallon, 275-gallon, shipping name on the tote, but the new totes don't have enough room on the marking 300-gallon, 400-gallon sizes?) Our practice has been that we stencil the proper plates for our current stencils (lettering requirement per DOT is 2" high letters). However, this information is included on the product label which is affixed to the tote. Do we still need to stencil the proper shipping name on the IBC tote with 2" high letters?. And if, stenciling IS required, can it be positioned from "top to bottom" as opposed to "left to right"? Could you please give me an official ruling. My fax number is 804-798-2205. Please follow up with hard copy to: John Mardigian ChemTreat, Inc. 10040 Lickinghole Road Ashland, VA 23005 Phone 804-935-2276#