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…
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.
“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: