• An IBC (intermediate bulk container) used for the transportation of a hazardous material (HazMat) must be designed, manufactured, tested, and marked to indicate it meets a packaging specification of the USDOT/PHMSA.
• The United Nations Performance Oriented Standard (aka: UN Standard) is one of several packaging specifications accepted for use within the U.S. by USDOT/PHMSA.
• An IBC that meets the UN Standard must display the UN Standard mark as specified at 49 CFR 178.703. This mark must be visible in transportation.

• In order to continue in service, IBCs must be retested and inspected as follows:
  • Leakproofness testing every 2.5 years if it is designed to retain liquids.
  • An external visual inspection every 2.5 years to ensure it continues to meet the requirements of the UN Standard.
  • An internal inspection every 5 years to ensure it continues to meet the requirements of the UN Standard.
• UN Standard packaging is not required for non-HazMat.

However…

• If a UN Standard packaging is used for a non-HazMat, the packaging is subject to all of the requirements of the UN Standard including the retest and reinspection.
• Therefore, if you use a UN Standard packaging for the transportation of a non-HazMat the IBC must continue to be retested every 2.5 years – and more as indicated above – in order to retain its UN Standard. It is a violation to use a packaging marked to indicate it meets the UN Standard when it does not.

Solution:

• Use IBCs that do not display the UN Standard mark for transport of non-HazMat.
• If UN Standard mark is visible, then obliterate, remove, or securely cover prior to transport of non-HazMat.