Q&A: What labels, marks, and placards are required on an IBC shipped domestically within the U.S. and internationally by vessel?

A question from a customer of mine who had attended my Onsite Training at their facility several months before:

Hi Dan,

I hope this finds you doing well.

During the training session back in April, there was a question raised about “do we need to apply a placard to IBCs (aka: intermediate bulk container) or can we use the 4” x 4” labels”. I cannot remember what the answer to this question was.

We ship a number of IBCs of Class 8 Corrosive Material not only domestically but also via ocean and today we place a class 8 placard on opposing sides of the IBC. Is this required or can we use the smaller 4” x 4” class 8 label?

Thanks for the help.

Best regards,

I was ready with an answer for the first half of his question but needed more time for the second part:

I can answer part of your question now. The other part will take more time and research. Please see below.

For transportation within the U.S. according to the regulations of PHMSA, there are several options for the marking, labeling, and/or placarding of an IBC. One option available is to mark and label the IBC in the same manner as a non-bulk packaging. This means a single HazMat label (4″ x 4″) near the proper shipping name and the identification number (ID number at least 12 mm high). This article I wrote explains the available options, including the above: How to Mark, Label, and/or Placard an IBC of HazMat.
The requirements for hazard communication on an IBC per the Dangerous Goods Code of the International Maritime Organization (IMO) are not immediately known to me. I will need to research the answer and reply.

I hope this helps.

That gave some satisfaction…

Thanks Dan!!

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But then I had some work to do…

I now have an answer to the second part of your question. Please see below.

Per the IMDG Code (i.e. the regulations of the IMO), an IBC of more than 450 L (119 gal) must be marked on two opposing sides (5.2.1.4) and must be labeled on two opposing sides (5.2.2.1.7).
This differs from the domestic regulations of PHMSA which has many options but includes an option to label and mark on only one side.

I hope this helps. Please contact me with any other questions.

The answer still required some clarification:

Hi Daniel,

Thanks for this information. The last part of our question relates to the size. Today we place a placard on each side of the tote but we are wondering if we can use a 4” x 4” label instead. This would be easier and less costly.

Thanks again.

And clarification was forthcoming:

In both instances (domestic and international) a 4″ x 4″ HazMat label is acceptable.

And appreciated!

Thanks!!!!!!

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, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Conclusion:

It’s not that uncommon that days, weeks, months, or even years after a training session a customer reaches out to me for clarification on some aspect of the regulations. I don’t charge for these services and answer questions gladly! I understand that the day – or days – of Onsite Training can be overwhelming. It may take sometime to process the information and apply it to your regulated activities; that’s when the questions come up. In the case of this customer my training was my second time to their site to provide the following training over the course of two days (16 hours):

If you need any of the above training and/or Hazardous Waste Personnel Training required by the USEPA, please don’t hesitate to contact me.