A question from a repeat customer on June 8, 2017. (I’m frequently contacted by customers in the interim between their periodic training to answer questions).
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 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 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,
|
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 |
My reply that same day:
Thank you for contacting me.
- 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 regulations of the IMO are not immediately known to me. I will need to research the answer and reply.
I hope this helps.
He was grateful, but I wasn’t done!
Thanks Dan!!
It took me until the next day to research the Dangerous Goods Code of the International Maritime Organization (IMDG Code):
I now have an answer to the second part of your question. Please see below.
- Per the IMDG Code, 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.
His reply the same day (06.09.17):
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.
I wished to clarify the information:
In both instances (domestic and international) a 250 mm x 250 mm (approximately 4″ x 4″) HazMat label is acceptable.
Wow! Look at all those exclamation marks! I think I helped him to save his company a lot of money!
Thanks!!!!!!
|
Interested in site specific training at your site that covers this topic, and more! Ask me about my Onsite Training |
Conclusion:
This exchange illustrates several important points about the applicable regulations and my services:
- The transportation of hazardous materials is subject to a variety of regulations based on its mode – aircraft, vessel, rail, or highway – and its destination – domestic or international.
- My International Maritime Organization (IMO) training will meet the requirements of the regulations and will inform you of ways that you can comply with the regulations and save money.
- It costs money to comply with the regulations but there are ways for a business to save money without violating the regulations. The options available for the labeling, marking, and/or placarding of IBCs is just one example of that.