The Journal of HazMat Transportation's™ Exclusive Comments on Current U.S. DOT Letters of Interpretation of the Hazardous Materials Regulations

摘要

With the same interpretation having been issued by PHMSA's Office of Chief Counsel addressed to three persons and it leading to the withdrawal of two previous interpretation letters, it seems appropriate to consider these letters. The subject involves the repair of composite IBCs (e.g., UN31HA1 IBCs) in accordance with §180.352(d). These IBCs typically consist of a metal cage surrounding a rigid plastic inner commonly referred to as a "bottle." Composites are the most common type of IBC in use for liquids, and in an age of recycling, they are commonly reused. To prepared them for reuse, used IBCs are typically subject to "routine maintenance," "repair," or "remanufacture" as defined in § 180.350(a), (b), and (c). Similar terms and related requirements were first included in the UN Model Regulations twelfth edition completed in 2000. The requirements became effective in the various regulations, including the HMR, at the beginning of 2003.