INDSPEC Chemical Corporation — Hazardous Materials Safety Interpretation

Page 1: • U.S.Department of Transportation 400 Seventh Street, S.W. Washington. D.C. 20590 esearch an diministration OCT 3 2002 Ms. Vicki H. Weightman INDSPEC Chemical Corporation Reference No.: 02-0195 1010 William Pitt Way Pittsburgh, PA 15238 Dear Ms. Weightman: This is in response to your letter requesting clarification on the requirements for IBCs under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). I apologize for the delay in answering and hope it has not caused you any inconvenience. Your questions are paraphrased and answered below: Q1. Does a successful vibration test indicate a flexible IBC is sift proof? Al. A flexible IBC must be capable of withstanding the vibration test without rupture or leakage. If there is no rupture and or release of material, the IBC is considered sift proof. Q2. What is the definition of water resistant? A2. The HIMR, at § 171.8, define "water resistant" as "having a degree of resistance to permeability by and damage caused by water in liquid form." Q3. Is a coated flexible IBC considered water resistant? coating must resist the penetration of water in order to meet the HMR standard. A3. The purpose of the coating is to make the IBC "water resistant" or "waterproof." The Q4. Is a 13H2 flexible IBC considered sift proof and water resistant under the current HMR? A4. The marking "13H2" on a flexible IBC indicates that the IBC is made of woven plastic and coated. It is the opinion of this office that the IBC meets the requirements for "sift-proof" and 'water-resistant" in $ 178.704 if the IBC resists the penetration of water and is capable of passing the vibration test without rupture or leakage. 178,710 020195#

Page 2• • I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3JUL. 22.2002 1:11PM INDSPEC HARMARVILLE NO. 8270 P. 2 INDSPEC Chemical Corporation T010 William Pilt Way, Pittsburgh, PA 15238 • Telephone 412-826-3666 • FAX 412-826-9699 CREAD IT Cortorn July 22, 2002 172.102 1PЗ 178.710 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards IBC U.S. Department of Transportation Research and Special Programs Administration 02-0195 400 7th Street SW Washington, D.C. 20590-0001 Fax: 202-366-3012 Dear Mr. Mazzulio, I am writing to you to request a written regulatory interpretation regarding special states that Flexible IBCs must be sift proof and water resistant or must be fitted with a provisions for Flexible IBCs identified under 49CFR172.102, IP Codes. Specifically IP3 sift proof and water resistant liner. Currently, Flexible IBCs require a vibration test. Does the vibration test indicate that the Flexible IBC is sift proof? What is the definition for water resistant? Is a coated Flexible IBC water resistant: for sift proof and water resistant? Under the current DOT regulations, does the 13H2 Flexible IBC meet the requirement I appreciate your time in this interpretation. I can be reached at 412-826-3669 if there are any questions. Sincerely, INDSPEC Chemical Corporation VHW/pib icki H. Weightma#