{"operation":"document","citation":"15-0047","title":"Columbus Chemical Industries — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-09-10","effective_on":null,"summary":"15-0047 response to Columbus Chemical Industries concerning 180.350, 180.352.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0047.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0047.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0047","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/150047.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n1200 New Jersey Avenue SE\nWashington, DC 20590\nPipeline and Hazardous\nMaterials Safety\nAdministration\nSEP 1 O 2015\nMs. Laura Buholca\nTechnical Manager\nColumbus Chemical Industries\nN4335 Tempkin Road\nColumbus, WI 53925\nRef. No. 15-0047\nDear Ms. Buholca:\nThis responds to your March 12, 2015 email requesting clarification on the recertification\nrequirements for intermediate bulk containers (IBCs) under §§ 180.350 and 180.352 of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if\nrecertification is required every 2.5 years starting from the date of manufacture or the date of\nfirst fill.\nIn your letter, you state that it is your understanding that recertification must take place 2.5\nyears from date of manufacture; however, you have received feedback from colleagues that\nit is required 2.5 years after the date of first fill. Additionally, it is your understanding that\nthe inner container (liners) must be replaced some period of time after the date of\nmanufacture (as identified by the manufacturer), not after the first fill.\nYour understanding is correct. The retest and inspection periods are based on the date of\nmanufacture, not the date of first fill. Specifically, § 180.352 requires that retests and\ninspections be performed on IBCs based on the date of manufacture or the date of repair in\naccordance with paragraphs (b) and (d) of this section. However, in accordance with\n§ 180.350(c)(2), routine maintenance on plastics or textile flexible IBCs is the routine\nperformance of operations such as: (1) cleaning; or (2) replacement of non-integral\ncomponents, such as non-integral liners and closure ties, with components conforming to the\noriginal manufacturer's specification; provided that these operations do not adversely affect\nthe containment function of the flexible IBC or alter the design type. Therefore, for non-\nintegral liners, you may rely on the manufacturer's guidarice for replacement timeframes.\nI hope this answers your inquiry. If you need additional assistance, please call this Office at\n202-366-8553.\nSincerely;\nNih M. 21.\nDirk Der Kinderer\nActing Chief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n•=\nBoaxie\n3180. 30 Upplicbilit\nind definition\nDodd, Alice (PHMSA)\n$180.352 Requerements for\nretest and inspection BIBCS\nFrom:\n15-0047\nSent:\nCiccarone, Michael CTR (PHMSA)\nTo:\nFriday, March 13, 2015 9:52 AM\nSubject:\nHazmat Interps\nFW: Requesting formal letter of interpretation\nShante/Alice,\nPlease submit this for a formal letter of interpretation. I spoke with Ms. Buchola the other day.\nThanks,\nMike\nFrom: Laura Buholca [mailto: Ibuholca@columbuschemical.com]\nSent: Thursday, March 12, 2015 4:52 PM\nTo: INFOCNTR (PHMSA)\nSubject: Requesting formal letter of interpretation\nGood afternoon,\nI would like to request formal letter of interpretation regards 49 CFR 180.350 and 352 - IBC recertification and IBC inner\nbottle replacement. Is recertification required 2.5 and 5 years from date of manufacture or date of first fill. My\nunderstanding is is that recertification has to take place 2.5 yrs from date of manufacture, however, l've received\nfeedback from my colleagues that it is date of first fill. Also - inner container(liner) - my understanding is that liner\nneeds to be replaced after x month after manufacture (as identified by manufacturer), not x mont afer first fill. Could\nyou please clarify.\nBest regards,\nLaura Buholca\nTechnical Manager\nColumbus Chemical Industries\nN4335 Temkin Road\nColumbus, WI 53925\n920-623-2140 ext. 114","truncated":false,"body_characters":3597}