Around the Fourth of July Holiday in 2016 I sent a “What’s up?” email to several past contacts. One of them responded with this question:
Daniels Training Services
It took awhile, but almost two months later I responded:
I have an answer for you!
- Per 49 CFR 173.35 General requirements for HazMat in IBCs, it is the responsibility of the shipper to ensure the markings required by 49 CFR 178.703 are present on an IBC before transportation.
- 49 CFR 178.703 Marking of IBCs, requires the manufacturer of an IBC to mark it in a durable and clearly visible manner in the following sequence (49 CFR 178.703(a)):
- United Nations symbol (UN).
- Code number designating IBC type.
- Capital letter (X, Y, or Z) indicating performance standard.
- Month (designated numerically) and year (last two digits) of manufacture.
- Country authorizing the allocation of the mark. e.g. USA indicates IBC is manufactured and marked in the U.S. in compliance with the USDOT Hazardous Material Regulations.
- The name and address or symbol of the manufacturer of the IBC.
- The stacking test load in Kg. ‘0’ = not designed for stacking.
- The maximum permissible gross mass of the IBC and HazMat in Kg.
- Additional markings are required at 49 CFR 178.703(b)(1) for rigid plastic & composite IBCs.
- No sequence is specified.
- Markings must be near the required markings (see above) and readily accessible for inspection.
- Where units of measure are used, metric unit (i.e. Kg or L) must be included in marking.
- Rated capacity in L of water.
- Tare mass in Kg.
- Gauge test pressure in kPa.
- Date of last leakproofness test, if applicable (month and year).
- Date of last inspection (month and year).
- General requirements:
- Required markings:
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
International and Domestic
Daniels Training Services
As a teaser, I provided him with the following:
- The General Specification Marking Requirements for Packagings
- Specification Packaging Requirements for IBCs
- Additional Requirements for Specification Packaging Markings on IBCs
- 49 CFR 172.504(a) requires placards on each side and each end of a vehicle required to display placards.
- 49 CFR 172.516(a) requires placards to be clearly visible from the direction it faces, except when facing the tractor of a tractor/trailer combination.
- The requirement of 49 CFR 172.516(a) may be met by the placards displayed on the vehicle or on the load itself if the display meets all of the requirements, i.e., readily visible, on background on contrasting color, clear of appurtenances and devices, &etc. This PHMSA interpretation letter addresses this issue: 10-0075.