IBC Residue, Choosing Placards, IATA Special Provisions, and Hazard Class Label Size
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.
Residue in IBCs (TDG)
- Q. Under TDG, do Intermediate Bulk Containers (IBCs) such as tote tanks that contain residues still have to be transported as dangerous goods? Should the placards remain or be removed?
- A. Under TDG, packagings or containers that still contain enough residue to pose a hazard during transportation should still be treated as dangerous goods. Unfortunately, the regulations do not give a specific way of judging this, so they should be considered hazardous unless you are absolutely sure they are not. (There is some misinformation that you may come across about how to make this decision. TDG does not specify “triple-rinsing” as a standard for cleaning or declare that an inch or less of residue can be considered non-dangerous. These references may come from other regulations or industry guidelines, but do not apply to TDG.)
So, if your IBC contains a dangerous residue, it should be clearly identified as such for transportation. If it was originally placarded or labelled correctly, just leave those Continue Reading…