Container Specialties Group — Hazardous Materials Safety Interpretation

Page 1- of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. Research and Special Programs Administration FEB 19 2002 Mr. Jake Mailey Ref. No. 01-0321 Container Specialties Group P.O. Box 5032 Evanston, IL 60204-5032 Dear Mr. Mailey, This is in response to your letter dated December 13, 2001, requesting clarification on the retest requirements for an Intermediate Bulk Container (IBC). Specifically you ask if the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180) require an IBC to be cleaned prior to retesting. The answer is no. The HMR do not require an IBC to be cleaned prior to a retest. However, it may be unsafe to test an IBC with certain hazardous materials remaining in the packaging, herefore, it is recommended that an IBC be cleaned prior to retesting. I hope this satisfies your request Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Material Standards ШИНН 1M 8,803 010321#

Page 2DEC-13-2001. 04:17P FROM: CONTAINER SPECIALTIE 7732628502 TO: 12023663012 P: 2/2 CSG BAH CONTAINER SPECIALTIES GROUP $ 178.803 Thursday, December 13, 2001 Testine J.S. DEPT. OF TRANSPORTATION EDWARD MAZZULLO IBC 01-0321 DEAR MR. MAZZULLO: I HAVE A QUESTION REGARDING THE PROCEDURE FOR RECERTIFYING INTERMEDIATE BULK CONTAINERS. MUST THE CONTAINER BE WASHED OUT PRIOR TO TESTING OR IS IT ACCEPTABLE THAT IT JUST BE EMPTY TO TEST. I ASKED THIS QUESTION OF MR. CAMERON SATTERTHWAITE AND WAS TOLD THAT THERE WAS NOTHING IN THE REGULATIONS THAT REQUIRED THE CONTAINER TO BE CLEAN PRIOR TO TESTING. MAY I PLEASE HAVE SOMETHING IN WRITING THAT STATES THIS FOR MY FILES. Sincerely. ahe 67 Jake Mailey P.O. Box 5032 • Evanston, IL 60204-5032 • (773) 262-8502 • FAX (773) 262-8590#