Bonar Plastics, Inc. — Hazardous Materials Safety Interpretation

Page 1Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and JAN 25 2007 Hazardous Matericils Safety Administration Mr. Craig Heinze 1005 Atlantic Drive Bonar Plastics, Inc. Ref. No.: 06-0268 West Chicago, IL 60185 Dear Mr. Heinze: IBC's under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You This is in response to your November 17, 2006 letter regarding testing requirements fo describe the IBC as a plastic bottle with two different sized openings in the bottle top, eight different possible fittings. You ask if the IBC may utilize a single certification nine inches and two inches. You provided pictures of the IBC with an arrangement of number, provided it is successfully tested with each of the eight different fittings. Section 178.801(d) requires design qualification testing at the start of production of each new or different IBC design type. Section 178.801 defines a "different IBC design type" as one that differs from a previously qualified IBC design type in structural design, size, material of construction or wall thickness, but does not include a packaging that differs in service equipment. Section 178.700(c)(2) defines service equipment to mean filling and instruments. An IBC may be certified as a single design type provided: (1) the fittings discharge, pressure relief, safety, heating and heat-insulating devices and measuring qualification testing requirements with service equipment representative of each of the meet the definition of service equipment; and (2) the IBC successfully passes the design representative service equipment used for testing the IBC, is required to be documented fittings described in your letter. Note that, a description of the design type, including the under the recordkeeping requirements in § 178.801(I). contact this office. I hope this information is helpful. If you have further questions, please do not hesitate to Sincerely, Office of Hazardous Materials Standards 178.700 060268 178.801 (1)#

Page 2Eichenlaub $178.700 Definitions 11/17/06 06-8268 To whom it may concern, This letter is to request that Bonar Plastics be allowed to consolidate combinations of various service equipment, as defined in CFR 49 178.700c(ii), to collectively be included on one UN/DOT certification number, for a given size IBC. In particular, Bonar Plastics makes several combinations of B120 IBC's. There are two applicable permutations. The following fittings will be included in our testing: For the 9" opening: 1. IPS Micromatic valve: Tanan#

Page 32. TCC Micromatic valve: 3. Combi-Vent:#

Page 44. Flowserve pump: 5. SHURflo pump: SHERRO.#

Page 5For the 2" openings: 1. IPS Micromatic valve: 2. TCC Micromatic valve: 3. BE vent:#

Page 65. Blank (no hole): Again, it is our sincere hope that with successful passage of various combinations of all incorporating these components. fittings above, we can utilize one UN/DOT certification number for our production needs Please contact me at your earliest convenience for clarification or direction on this most important matter. Thank you. Craig Heinze Quality Engineer Bonar Plastics, Inc. 1005 Atlantic Drive West Chicago, IL 60185 (630) 293-0303#