Brenntag Southeast, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration JUL 9 2007 Mr. Bruce Biehl Director of Regulatory Affairs Ref. No. 07-0098 2000 E. Pettigrew Street Brenntag Southeast, Inc. Durham, NC 27703 Dear Mr. Biehl: This responds to your letter requesting clarification of the IBC marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the portable tank marking requirements in § 172.326 also apply to an IBC. In § 172.302(a) on an IBC are not visible, the transport vehicle or freight container must be addition, you ask for confirmation that if the identification number markings required by marked as required by § 172.332 on each side and each end with the identification number specified in the § 172.101 Table. The marking requirements specified in § 172.326 apply only to portable tanks. In addition, your understanding of the identification number marking requirements for an IBC in §§ 172.331 and 172.332 is also correct. 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 172•326 1725/ 070098#

Page 2• Brenntag Southeast, Inc. • BRENNTAG Stevens May 7, 2007 3|12.33l 3/1L•32° Tarkinas ot IRC Mr. Edward T. Mazzullo 01-0098 Director, Office of Hazardous Materials Standards 1200 New Jersey Avenue, SE East Building, 2nd Floor U.S. DOT/PHMSA (PHH-10) Washington, DC 20590 Dear Mr. Mazzullo: Danny of your office regarding the marking requirements of Intermediate Bulk This letter is to request verification of an email and subsequent phone conversation with Containers, IBC. 173.302(b) gives requirements for other markings on certain containers. I want to confirm that IBC containers are to be marked in Accordance with 172.331, Bulk packaging other than portable tanks, cargo tanks, tank cars and multi-unit tank car tanks, transport vehicle or freight container, if the identification number marking on the bulk as specifically referenced in 172.331(c), For a bulk packaging contained in or on a packaging (e.g., an IBC) required by § 172.302(a) is not visible, the transport vehicle or freight container must be marked as required by § 172.332 on each side and each end with the identification number specified for the material in the § 172.101 Table In addition that section 173.326 applies to Portable Tanks not IBC. Thank you in advance for your response. Sincerely, Bruce Biehl Director of Regulatory Affairs Bedford, VA • 540-586-6380 2000 E. Pettigrew Street Brenntag Southeast, Inc. Charlotte, NC • 704-588-1820 Charleston, SC • 843-744-7421 Durham. NC 27703 Duncan, SC • 864-879-7000 919-596-0681 Florence. SC • 843-744-7421 Greensboro. NC • 336-292-5166#