URS Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Ave. SE Washington. D.C. 20590 Pipeline and Hazardous Materials Safety Administration APR 1 9 2010 Ms. Erin Jarman Environmental Scientist DRS Corporation 1600 Perimeter Park Drive, Suite 400 Morrisville, NC 27560 Ref. No. 1O~0060 Dear Ms. Jarman: This responds to your March 16, 2010 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171~180) as they apply to Intermediate Bulk Containers (IBCs). Specifically, you ask for clarification of the language in § 180.352(b)(2)(iii) that states, "The inner receptacle of a composite IBC must be removed from the outer body for inspection unless the inner body is bonded to the outer body or unless the outer body is constructed in such a way (e.g., a welded or riveted cage) that removal ofthe inner receptacle is not possible without impairing the integrity of the outer body." Your questions are summarized and answered as follows: Q1) Would an inner body of a composite IBC that is secured into the outer body by straps that are welded and that would require cutting have to be removed from the outer body for inspection? AI) No. The HMR do not require attachments that are welded to the outer body to be removed prior to inspection. Q2) Would an inner body of a composite IBC that is secured into the outer body by straps that are crimped and that would require cutting have to be removed from the outer body for inspection? A2) Yes, provided cutting the crimped attachments would not affect the integrity of the outer body. Q3) Would an inner body of a composite IBC that is secured into the outer body with straps having bolted fasteners have to be removed from the outer body for inspection?#

Page 2A3) Yes, provided removal of the inner body would not affect the integrity of the outer body. I hope this information is helpful. If you have further questions, please contact this office. Sin:t'~ Charles E. Betts Chief, Standards Development e of Hazardous Materials Standards#

Page 3EI~uh~!~ ~ 190 r3:,i-llo)(2) riP) TBc..!s lD- 00(00 March 16,2010 Mr. Edward T. Mazzullo Director, Office ofHazardous Materials Standards U.S. DOT/PHMSA (PHH-1O) 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 Dear Mr. Mazzullo: I am writing to you with regards to the retest and inspection requirements for composite IBCs found in 49 CFR §IS0.352(b)(2)(iii). Specifically, the language in 49 CFR §180.352(b)(2)(iii) states the following: "The inner receptacle of a composite IBC must be removed from the outer body for inspection unless the inner body is bonded to the outer body or unless the outer body is constructed in such a way (e.g., a welded or riveted cage) that removal ofthe inner receptacle is not possible without impairing the integrity of the outer body." There has been a growing debate among various IBC retesters as to whether an inner body ofa composite IBC that is secured inside an outer body by metal straps or bolted fasteners would need to be removed in order to facilitate a proper inspection. Some retesters feel that the above language permits them to leave the inner body in the outer body ofthe IBC during inspection. On the other hand, some feel that since the metal straps can be cut or unbolted, removal of the inner body from the outer body is not impossible and should therefore be done for proper inspection. My questions are as follows: I) Would an inner body ofa composite IBC that is secured into the outer body by straps that are welded and which would require cutting have to be removed from the outer body for inspection? 2) Would an inner body of a composite IBC that is secured into the outer body by straps that are crimped and which would require cutting have to be removed from the outer body for inspection? 3 ) Would an inner body of a composite IBC that is secured into the outer body by straps having bolted fasteners have to be removed from the outer body for inspection? Thank you in advance for your assistance. I look forward to your response. Sincerely, Erin N. Jarman Environmental Scientist URS Corporation 1600 Perimeter Park Drive, Suite 400 Morrisville, NC 27560 Tel: 919-461-1478 Erin_Jarman@urscorp.com#