Cuttings Box Packing Regulations

The design, manufacture and testing standards for the 15 and 25 BBL Cuttings Boxes are listed in the Code of Federal Regulation, Title 49. These standards are self-certifying. This means that it is the responsibility of the container manufacture to meet all of the requirements for the type of container being constructed and to mark the container accordingly. All containers meeting a standard or specification must be marked with the standard or specification number. The Department of Transportation and Coast Guard do not issue approval or certification paper work for containers.

The 15 BBL cutting container falls under the United States Department of Transportation standards for INTERMEDIATE BULK CONTAINER PERFORMANCE-ORIENTED PACKAGES. The design, construction, and testing standards for this container are specified in the Code of Federal Regulations, Title 49, Sections 178.700 and 178.800. The 15 BBL containers are designed, tested, and manufactured in accordance with all of the requirements detailed in these sections and the containers are marked to indicate this as required in the regulations. The UN symbol denotes compliance with the standards. 31A/Y identifies the container as a steel intermediate bulk container for liquids meeting the test requirements for packing group II and III materials. The Modern Group is registered with the Department of Transportation as an Intermediate Bulk Container Manufacture. The Modern Group registration number is M5256.

The volume capacity of a 25 BBL exceeds the maximum capacity limit for an Intermediate Bulk Container. Therefore, the 15 BBL specifications cannot be applied to the 25 BBL unit. In fact, there is no conventional Department of Transportation packaging standard that applies to containers of this size. The Code of Federal Regulations, Title 49, Section 176.340 details the requirements for the design, testing, manufacture, and use of non-specification portable tanks to carry combustible liquids by vessel. The 25 BBL containers are designed, tested, and manufactured in accordance with all of the requirements of this section and are marked to indicate this as required by regulations. The required marks, “FOR COMBUSTIBLE LIQUIDS ONLY” and “49 CFR 176.340”, certify that the container conforms to the regulation.

In the past many cuttings containers were produced that did not meet the standards for a conventional specified container. The containers were then reviewed by the Coast Guard before they could be used for combustible liquids. If the container was approved for the use the Coast Guard would issue a letter of authorization and the container would be marked “USCG LOA” followed by the authorization number. Many containers with this marking are still in use today. A container that meets the requirements of sections 49 CFR 176.340 or 178.700, and 178.800 will not be issued a letter authorization because by meeting the standards it is already authorized for use. Therefore, any container meeting the above standards will not have the “USCG LOA” markings.