{"operation":"document","citation":"10-0060","title":"URS Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-04-19","effective_on":null,"summary":"10-0060 response to URS Corporation concerning 180.352.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0060.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0060.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0060","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100060.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Ave. SE\nWashington. D.C. 20590\nPipeline and Hazardous Materials\nSafety Administration\nAPR 1 9 2010\nMs. Erin Jarman\nEnvironmental Scientist\nDRS Corporation\n1600 Perimeter Park Drive, Suite 400\nMorrisville, NC 27560\nRef. No. 1O~0060\nDear Ms. Jarman:\nThis responds to your March 16, 2010 letter requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171~180) as they apply to Intermediate Bulk Containers\n(IBCs). Specifically, you ask for clarification of the language in § 180.352(b)(2)(iii) that states,\n\"The inner receptacle of a composite IBC must be removed from the outer body for inspection\nunless the inner body is bonded to the outer body or unless the outer body is constructed in such\na way (e.g., a welded or riveted cage) that removal ofthe inner receptacle is not possible\nwithout impairing the integrity of the outer body.\" Your questions are summarized and\nanswered as follows:\nQ1) Would an inner body of a composite IBC that is secured into the outer body by straps that\nare welded and that would require cutting have to be removed from the outer body for\ninspection?\nAI) No. The HMR do not require attachments that are welded to the outer body to be removed\nprior to inspection.\nQ2) Would an inner body of a composite IBC that is secured into the outer body by straps that\nare crimped and that would require cutting have to be removed from the outer body for\ninspection?\nA2) Yes, provided cutting the crimped attachments would not affect the integrity of the outer\nbody.\nQ3) Would an inner body of a composite IBC that is secured into the outer body with straps\nhaving bolted fasteners have to be removed from the outer body for inspection?\n\n<<<PAGE 2>>>\n\nA3) Yes, provided removal of the inner body would not affect the integrity of the outer body.\nI hope this information is helpful. If you have further questions, please contact this office.\nSin:t'~\nCharles E. Betts\nChief, Standards Development\ne of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nEI~uh~!~\n~ 190 r3:,i-llo)(2) riP)\nTBc..!s\nlD- 00(00\nMarch 16,2010\nMr. Edward T. Mazzullo\nDirector, Office ofHazardous Materials Standards\nU.S. DOT/PHMSA (PHH-1O)\n1200 New Jersey Avenue, SE East Building, 2nd Floor\nWashington, DC 20590\nDear Mr. Mazzullo:\nI am writing to you with regards to the retest and inspection requirements for composite IBCs found\nin 49 CFR §IS0.352(b)(2)(iii). Specifically, the language in 49 CFR §180.352(b)(2)(iii) states the\nfollowing:\n\"The inner receptacle of a composite IBC must be removed from the outer body for inspection\nunless the inner body is bonded to the outer body or unless the outer body is constructed in such a\nway (e.g., a welded or riveted cage) that removal ofthe inner receptacle is not possible without\nimpairing the integrity of the outer body.\"\nThere has been a growing debate among various IBC retesters as to whether an inner body ofa\ncomposite IBC that is secured inside an outer body by metal straps or bolted fasteners would need to\nbe removed in order to facilitate a proper inspection. Some retesters feel that the above language\npermits them to leave the inner body in the outer body ofthe IBC during inspection. On the other\nhand, some feel that since the metal straps can be cut or unbolted, removal of the inner body from\nthe outer body is not impossible and should therefore be done for proper inspection.\nMy questions are as follows:\nI) Would an inner body ofa composite IBC that is secured into the outer body by straps that are\nwelded and which would require cutting have to be removed from the outer body for inspection?\n2) Would an inner body of a composite IBC that is secured into the outer body by straps that are\ncrimped and which would require cutting have to be removed from the outer body for inspection?\n3 ) Would an inner body of a composite IBC that is secured into the outer body by straps having\nbolted fasteners have to be removed from the outer body for inspection?\nThank you in advance for your assistance. I look forward to your response.\nSincerely,\nErin N. Jarman\nEnvironmental Scientist\nURS Corporation\n1600 Perimeter Park Drive, Suite 400\nMorrisville, NC 27560\nTel: 919-461-1478\nErin_Jarman@urscorp.com","truncated":false,"body_characters":4246}