{"operation":"document","citation":"05-0299","title":"Akzo Nobel Chemicals — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-02-03","effective_on":null,"summary":"05-0299 response to Akzo Nobel Chemicals concerning 178.703, 178.801, 180.350.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0299.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0299.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0299","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050299.pdf","body":"<<<PAGE 1>>>\n\nMr. Mark A Connolly\nRef. No. 05-0299\nManager Transportation Regulations\nand Security\nAkzo Nobel Chemicals\n300 South Riverside Plaza\nChicago, IL 60606-6697\nmust\nDear Mr. Connolly:\nThis is in response to your October 7, 2005 letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you seek\nclarification regarding the specification plate markings for initial test and inspection of\nUN31A metal intermediate bulk containers (IBCs).\nAccording to your letter, your company recently purchased new UN31A IBCs for the\ntransportation of organic peroxides. These IBCs contain all of the information required\nby § 178.703(a) on a specification plate. Except for the month and year of the last\nleakproofness test and the month and year of last inspection, the IBCs are marked with\nthe additional information required by § 178.703(b)(2).\nIn accordance with § 178.813, a leakproofness test must be conducted for the\nqualification of all IBC design types and on all production units intended to contain\nliquids or solids loaded or discharged under pressure. Each IBC must also have an\nexternal visual inspection initially after production and every 2.5 years starting from the\ndate of manufacture. The month and year of the leakproofness test and last inspection\nmust be mari ed on each IBC as required by § 178.703(b) before an IBC may be filled\nand offered for transportation.\nThe person who certifies an IBC must keep records of design qualification tests in\naccordance with § 178.801(1).\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerély,\n/John A. Gale\nChief, Standards Development\nOffice of Hazardous Materials Standards\n178.703\n178.801\n180.350\n050299\n\n<<<PAGE 2>>>\n\nImportance: High\nI understand that you're working from home today -\nHope you are able to get out to the links this weekend - I'm going up to Lake Geneva Wisconsin Saturday to get\nin 36 holes - before the weather gets too cold...\nI need some clarification from you regarding the specification plate markings and initial test and inspection for\nmetal UN31A IBC's.\nWe have received some newly built IBC's made in China (built 09/05) for loading of organic peroxides. Akzo\nNobel is the owner of the new UN31A IBC's.\nI'm specifically looking at 49CFR 178,703 (a) (1) (D) (2); 178.80 1(1), 178,3/1(1); and 180.350.\nEach IBC metal specification plate is marked with the following:\nThe UN symbol: \"U/N inside a circle\"\nThe code designating the type of IBC: \"31A\";\nThe capital letter designating the package group: \"y\"\nThe month and year (last two digits) of manufacture: 08 05\"\nMature: 0805%\nThe country authorizing the Mark Connolly The name and or symbol of the manufacturer: \"CHINA/SPMMC\"\nThe stacking test load in kilograms. Since these are not designed for stacking the figure: \"0\"\nThe maximum permissible gross mass in kilograms: \"2300\"\n[IMO 6.5.2.1.1 and 49CFR 178.703 (a)(1)]\nAdditional markings that appear on the above noted specification plate:\nCapacity in liters at 20C: \"CAPACITY 1500 L\"\nTare mass in kilograms: \"TARE 512 KG\"\nMaximum filling or discharge pressure in kPa or bar if applicable: \"TEST PRESSURE 80KPA\"\nBody material and its minimum thickness in mm: \"SHELL MAT. 304 S.S. THKNS. 35 MM\"\nDate of Tast leakproof test, (month and year):*\nDate of last inspection (month and year):\n-Serial rumber of manüfacturer: \"SERIAL NO. 05-C-17-25\"\n[IMO 6.5.2.2.1 and 49CFR 178.703 (b)(2)]\nThe Chinese manufacture has provided us with documentation of pressure tests and Pneumatic tests conducted\nat their facility during production. Their documents are not a one to one ratio for each IBC serial number. They\nhave provided us with a summary of test and inspection documents that groups the IBC's into lots of 10\nWith the above noted specification plate marking (no date of last inspection and no date of last leakproof test) and\nthe summary document -\nIs the above noted information is sufficient for us to load these IBC's?\nOr do you recommend that we conduct our own Inspection prior to filling and conduct a leakproof test\nalong with an External visual and document it according to 178.801(1)?\nPlease call me at 312 544 7177\nMark A. Connolly\nManager Transportation Regulations and Security\n10/27/2005","truncated":false,"body_characters":4284}