IBC testing: Clarification of the term "filled"
Pipeline and Hazardous Materials Safety Administration · Oct 18, 2007 · Reference No. 07-0159
Interprets: 49 CFR § 178.819
Reggie’s quick take
Someone asked what "filled" means in the IBC vibration test rule, § 178.819(b)(1). The agency says "filled" means the IBC's maximum permissible gross mass. For example, an IBC marked with a 500 kg maximum gross mass must weigh 500 kg during the test. This applies even if the user plans to ship the package below that maximum.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your letter dated May 31, 2007 and subsequent telephone conversation with Ben Supko of my staff in regard to the IBC testing provided by the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the term "filled," as used in § 178.8l9(b)(1).
In preparation for the vibration test, § 178.819(b)(1) requires an IBC to be filled and closed as for shipment. The term "filled" represents the maximum permissible gross mass of the package - that is, an IBC marked with a 500 kg maximum gross mass must weigh 500 kg when subjected to the test. The requirement for performance of the vibration test on a "filled" package applies even if the end user plans to offer the package for transportation below its maximum permissible gross mass.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.