{"operation":"document","citation":"01-0286","title":"ChemTreat, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-06-10","effective_on":null,"summary":"01-0286 response to ChemTreat, Inc. concerning 172.332.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0286.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0286.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0286","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010286.pdf","body":"<<<PAGE 1>>>\n\n•\nJ.S. Department\nof Transportation\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\npeciai Program:\ndministratio:\nJUN 1 0 2002\nMr. John Mardigian\nRef. No. 01-0286\nChem Treat, Inc.\n10040 Lickinghole Road\nAshland, VA 23005\nDear Mr. Mardigian:\nThis responds to your letter regarding marking requirements under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180) for Intermediate Bulk Containers (IBCs) having capacities of 75, 275,\n300, or 400 gallons. Specifically, you asked if marking the proper shipping name of a hazardous\nmaterial in 50 mm (2.0 inches) letters on an IBC, by stenciling, is required; or, would such information\nalready included on a product label affixed to an IBC satisfy the marking requirements. In a subsequent\ntelephone conversation, with a member of my staff, you said that the 75 gallon capacity container was a\nnon-bulk packaging, not an IBC.\nAn IBC must be marked with an identification number as specified in §§ 172.302, 172.331 and\n172.332. The size of an identification number marking on an IBC must have a width of at least 4.0 mm\n(0.16 inch) and, with a capacity of less than 3,785 L (1,000 gallons), a height of at least 25 mm (one\ninch). An identification number marking for an IBC with a capacity of more than 3,785 L (1,000\ngallons) must be at least 50 mm (2.0 inches) in height. For an IBC contained in or on a transport\nvehicle or freight container, if the identification number marking on the IBC is not visible, the transport\nvehicle or freight container must be marked as required by § 172.332.\ncontuation. A produc be mayed on used to get lan lanie to suite e are ing display on\nan IBC.\n:\n332\n112.\n010286\n\n<<<PAGE 2>>>\n\nThe marking requirements for non-bulk packagings (i.e., having a capacity of less than 119 gallons) are\nfound in § 172.301. The 75 gallon capacity container is a non-bulk packaging, as defined in § 171.8,\nand must be marked with the proper shipping name and identification number. A product label may be\nused to satisfy the marking reguirements on a non-bulk packaging, such as the 75 gallon capacity\ncontainer, as long as it meets the general marking requirements in §§ 172.301 and 172.304.\nI hope this information is helpful. If we can be of further assistance, please contact us.\nSincerely,\nDelm 765 allo\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\n. 11/02/2001 15:42 FAX\nEngrum\n@001/001\n§112.337\n10040 Lickinghole Road\nAstland, VA 23005\nabelino\n\"|- 028g\nfacsimile transmittal\nTo: Ben\nFax:\nFrom: John Mardigian\nDate: Novembor 2, 2001\nRe:\nPages: CC:\ng Urgent\n• For Review\n• Please Comment\nX Please Reply O Please Recycle\n•\n•\n•\n•\n•\nWhat are the proper labeling requirements for shipping IBCs (75-gallon, 275-gallon,\nshipping name on the tote, but the new totes don't have enough room on the marking\n300-gallon, 400-gallon sizes?) Our practice has been that we stencil the proper\nplates for our current stencils (lettering requirement per DOT is 2\" high letters).\nHowever, this information is included on the product label which is affixed to the\ntote. Do we still need to stencil the proper shipping name on the IBC tote with 2\"\nhigh letters?. And if, stenciling IS required, can it be positioned from \"top to\nbottom\" as opposed to \"left to right\"? Could you please give me an official ruling.\nMy fax number is 804-798-2205. Please follow up with hard copy to:\nJohn Mardigian\nChemTreat, Inc.\n10040 Lickinghole Road\nAshland, VA 23005\nPhone 804-935-2276","truncated":false,"body_characters":3510}