ICC's Regulatory Helpdesk
Regulatory Helpdesk: October 1

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.

Placarding Bulk Truckloads

Q. My truck has 4000kgs of drums of Class 3 UN1993 in it. Truck has Class 3 UN1993 placard on it . We pick up 1 empty tote (IBC) which is Class 3 UN1993 also. Can we keep the same placard on the truck or do we need to add Class 3 only? Same with empty drums. We just need to add primary CLASS card? All transported via ground within Canada.
A.Well the drums don’t need UN numbered placards since drums are considered small means of containment. A plain class 3 placard will do to represent the drums. It used to be in the Regulations that over 4000kg from one shipper could display UN numbered placard but it was repealed recently. Totes, even empty with residue, requires UN numbered placards for liquids in direct contact with the means of containment. You don’t need to add plain class 3 placard for the drums as both the drum and tote content is hazard class 3. So technically the truck displayed the correct placard (UN1993). If the drums were empty and less than 500kg gross mass then no placard will be required; however, if you Continue Reading…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: July 30

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…

3D rendered IBC
New ASTM Standard for IBCs

Neatly stacked IBCs

ASTM IBC Standards

Recently I wrote a blog about our boxes meeting ASTM standards. For those that weren’t aware, I described ASTM International as an international standards organization that develops and publishes voluntary technical standards for a wide range of products including packaging. In addition to providing standards in the development of corrugated boxes, ASTM can provide guidance in testing hazardous materials packaging, specifically in this case hydrostatic testing of Intermediate Bulk Containers.

Hydrostatic Testing for IBCs is outlined in 49 CFR §178.803 and §178.814.

This states:

The hydrostatic pressure test must be conducted for the qualification of all metal, rigid plastic, and composite IBC design types intended to contain solids that are loaded or discharged under pressure or intended to contain liquids.

However, the current regulations have been described as “limited” on the specific details of how to perform the test. (See video below)

This guide provides the detail on how to conduct pressure testing on IBCs and will provide a more consistent process for container manufacturers, testing labs, and regulatory agencies. The new standard will thus help manufacturers pass performance tests and qualify their container designs to meet requirements of the U.S. Department of Transportation’s Title 49 Code of Federal Regulations as well as the United Nations recommendations on the transport of dangerous goods. The new standard will be published as ASTM D8134 and the scope is listed below:

Scope