Scranton Cooperage, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materials Safety APR 7 2006 Mr. Eric Spatt Reference No.: 06-0054 Scranton Cooperage, Inc. 1264 Mid Valley Drive Jessup, PA 18434 Dear Mr. Spatt: This responds to your letter concerning the markings on intermediate bulk containers (IBCs) required by § 180.352 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask what is meant by "durably mark the IBC near the manufacturer's UN design type marking." Section 180.352 requires the person performing routine maintenance on an IBC to durably mark the IBC with the country in which the routine maintenance is carried out and the name or means "able to exist for a long time without significant deterioration." It is our opinion that the authorized symbol of the party performing the routine maintenance. "Durable" generally required markings should remain on the IBC and be clearly legible until the next scheduled retest and inspection. I trust this satisfies your request. Sincerely: Hotte z moto Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 180.352 060054#

Page 2Corbin $180.352 IBC's MEMO 06-0054 FROM THE OFFICE SCRANTON COOPERAGE INC. 1264 Mid Valley Drive (570) 383-7244 Jessup PA. 18434 (570) 383-7250 FAX ericspatt@scrantoncooperage.com Date: 2-21-06 From : Eric Spatt Subject: Regulation interpretation Regulation Specialist, We at Scranton Cooperage Inc. M# 5154 are an IBC reconditioner and we need assistance in interpretation of a regulation §180.352 Requirements for retest and inspection of IBCs Sub Section E This a new regulation and we are not sure what is meant by durably mark the BC near the manufactures information of metal, rigid plastics and composite IBCs performed by the owner of the IBC, whose State e) Requirements applicable to routine maintenance of IBCs. Except for routine maintenance routine maintenance shall durably mark the IBC near the manufacturer's UN design type and name or authorized symbol is durably marked on the IBC, the party performing the marking to show the following: (e) (1) The County in which the routine maintenance was carried out; and (e)(2) The name or authorized symbol of the party performing the routine maintenance. Please advice and thank you for your assistance Soon Erig Spatt#