In accordance with 49CFR 178.2(c), closure instructions are required to be supplied by manufacturers and distributors of all UN certified packagings. Responding to an inquiry from a filler who owns their IBC fleet, PHSMA applied the applicability of 178.2(c), for the return of empty, used, Intermediate Bulk Containers (IBC‘s). In their response, PHMSA stated that yes, per 178.2(c)(1), each person to whom a packaging is transferred must be notified of all requirements not met at the time of transfer and must receive written closure instructions. It is the responsibility of the manufacturer or other person certifying compliance with Part 178, and each subsequent distributor of the packaging, to provide the notification. The applicability of this interpretation to a third party sale of the IBC was not addressed. PHMSA’s response was a bit unclear, but they appear to be suggesting that it is good practice for all persons transferring IBC‘s (and other UN packagings) to a third-party, to include closure instructions.