The USDOT/PHMSA Hazardous Materials Regulations identify three situations when a HazMat’s identification number must be displayed on a transport vehicle.
The transport vehicle itself is a bulk packaging (e.g., cargo tank, rail tank car).
If I opt to label an IBC as opposed to placard, and I mark in accordance with 49 CFR 172.301(a)(1), am I still required to display the UN ID marking on the outside of the transport unit as in §172.331(c)?
Answer:
Thank you for contacting me. Please see below.
Yes.
49 CFR 172.331(c) refers to the ID # on a bulk packaging. If the ID # on the bulk packaging is not visible when it is in or on the transport vehicle or freight container, then the ID # must be displayed on all four sides of the vehicle or freight container and be visible from the direction it faces.
The reference to §172.302(a) instead of §172.301(a)(1) may be confusing, but it is at §172.302(a) where the requirement to display the ID # on a bulk packaging is found along with, “except as otherwise provided in this subpart…” which opens the door for hazard communication as described at §172.301(a)(1).
In the end, the IBC remains a bulk packaging and §172.331(c) is still applicable.
I hope this helps. Please contact me with any other questions.
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I understand. So regardless of how the IBC was actually marked (labeled instead of placarded for instance) the marking is still not visible from the outside, and thus §172.331(c) applies.
Hello, Our company would like to know if the IBCs that are intended to be filled with non hazardous material need to be retested every 2.5 years. Does the DOT require this regardless of Hazardous / non hazardous material in the IBC?
Thank you,
My reply October 22, 2020:
Thank you for contacting me. Please see below.
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.
I hope this helps. Please contact me with any other questions.
He required clarification:
So, as long as the UN marking is off the tote, it can be shipped?
Interested in a Webinar that covers this topic, and more!
Sometimes the USDOT/PHMSA Hazardous Materials Regulations can be tricky; sometimes they don’t make any sense. “Why does it matter if the material in transport is non-HazMat?” My HazMat Employee training can help you to make sense of it all.
The Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) regulates the transportation in commerce of hazardous materials to, from, or through the U.S. In its Hazardous Materials Regulations (HMR) it defines and authorizes the use of a variety of packagings for the transportation of hazardous materials (HazMat). Just one of those packagings is the intermediate bulk container (IBC).
Intermediate bulk container (IBC) is defined at 49 CFR 171.8:
Intermediate bulk container or IBC means a rigid or flexible portable packaging, other than a cylinder or portable tank, which is designed for mechanical handling. Standards for IBCs manufactured in the United States are set forth in subparts N and O of part 178 of this subchapter.
An IBC may be either rigid or flexible. So, it may be self-supporting (maybe stackable) or it might be similar to a plastic bag that is only provided structure by the HazMat it contains.
It must be portable, which makes sense if you’re going to offer it for transportation.
It cannot be a cylinder (for compressed gases) or a portable tank. Here, as elsewhere when defining HazMat packaging, at least part of the packagings definition is based on what it is not.
It must be designed for mechanical handling. Though imprecise, I believe this is the key to the definition of an IBC. In this language USDOT/PHMSA indicates that whatever its appearance, the IBC is not designed to be moved by a person (as may be a drum, box, or jerrican). Instead, an IBC will have hooks, straps, be palletized, or have some other feature that allows it to be moved by equipment such as a fork truck or crane.
And…
An IBC manufactured in the U.S. must be made according to the performance-oriented standards in 49 CFR 178, subpart N and be tested per the requirements of 49 CFR 178, subpart O.
And that’s it!
Interested in a Webinar that covers this topic, and more!
The definition does not require an IBC to be a bulk packaging, i.e., have a capacity of more than 450 L (119 gal) even though the name includes the word “bulk”. Neither does the definition specify a minimum or maximum capacity as it does for the large packaging. Therefore, if it complies with the remainder of the definition, an IBC could have a capacity of no more than 1.3 L (5 gal), or less!
Where else is IBC mentioned?
Intermediate bulk container (IBC) is included in the definitions for the following in 49 CFR 171.8.
The definition of cargo tank specifies that it – the cargo tank – is not an IBC.
The definition of a UN portable tank specifies that an IBC may not be a UN portable tank.
49 CFR 173.35 is a section of the HMR dedicated just to the filling and offering for transport of HazMat in IBCs.
IBC is identified as an authorized packaging for a variety of HazMat in 49 CFR 173.
As you can see, the definition of an IBC is both simple and vague. Nowhere, not even in subparts N and O of part 178, does it mandate an appearance or specify a shape or design for the finished packaging. This presents both an opportunity and a challenge:
As an opportunity it allows the shipper to construct an IBC of any shape, size, or capacity to contain its HazMat.
A challenge in that sometimes you may not know if a packaging is an IBC unless it displays one of the packaging type codes designating it as an IBC:
11 for a rigid IBC that discharges solids by gravity.
13 for a flexible IBC that discharges solids by gravity.
21 for a rigid IBC that discharges solids under pressure of more than 10 kPa (1.45 psig).
31 for a rigid IBC designed for liquids.
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I have read your Bulk Packaging for hazmat. I have a questions regarding the aerosol cans packed in an 11G fiber cubic yd boxes (aka: an intermediate bulk container or IBC). You have confirmed placards and UN numbers are not required due to inner containers. If boxes do display placards 2.1 with the 1950 across in the white panel would this be a violation for over placarding?
Thanks for your help.
My reply the same day:
Thank you for contacting me. I will try to answer your questions. Please see below.
I presume you are referring to the following Q&A at the end of the article:
Q: Are aerosol cans loaded in a UN specification bulk packaging, i.e. an 11G fiberboard Intermediate Bulk Container (IBC) subject to the marking, labeling and placarding requirements for a bulk packaging?
A: No. The definition of a bulk packaging specifies that it must contain hazardous materials that are loaded with no intermediate form of containment. The aerosol cans in the 11G box would be a form of intermediate containment and, thus, not considered a bulk packaging. It is interesting that in this situation what may start as a bulk packaging may not continue to meet the definition depending on how it is used.
As a rule, using hazard communication in excess of what is required, as long as the HazMat is present and other conditions are met, is not a violation.
I will need more information about your situation: Are the aerosols in this case being transported as a waste for disposal or recycling?
Please advise.
Some more information on June 11, 2020:
Thanks Daniel for helping me.
I did call the DOT hotline and since the cubic yard box is acting as on overpack for the aerosol cans the placard with the UN number across the middle would not apply. I looked at Large Packaging requirements which do contain inner containers but the 11G IBC does not meet the requirements of a Large packaging since it does not exceed 119 gallons.
We are shipping these for disposal (hazardous waste).
We normally have the yellow haz waste marking with all the generator information, shipping description etc and a 2.1 placard with 1950 across the middle on two opposite sides of the IBC. Would this still be acceptable by DOT or a violation?
Thanks so much for your help.
Interested in site specific training at your site that covers this topic, and more!
I will do my best to answer your question and provide guidance. Please see below.
I believe the Q&A in my article on bulk packaging & your call to DOT confirms the cubic yard box with aerosols is not a bulk packaging. Therefore, it could display the labels and marks as if it is a non-bulk packaging.
Non-bulk packagings must be display labels in compliance with 49 CFR 172, subpart E.
A placard with the ID # displayed on it will not meet the specifications of a label. I believe it would be a violation to display the placard instead of the required label.
However, it is not a violation to use hazard communication in excess of what is required as long as the hazard is present. You could display the placard in addition to the label, but not in place of it.
There is a good exception from full regulation for aerosols shipped for disposal or recycling at 49 CFR 173.306(k). Using it makes discussion of labels and placards on the cubic yard box unnecessary.
Thanks for your help. I start confusing myself when reading and rereading the requirements.
Conclusion:
There’s no shame in admitting you may become confused by the regulations (it happens to me all the time). The solution is to sit down and carefully review the regulations, guidance documents, and interpretation letters of the respective agency until you can finally make sense of it all. Or call me.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
We have about forty 1,000 pound super sacks that we need to ship for disposal before the end of the year.
They will ship as Environmentally hazardous Substance Solid nos UN 3077.
Waste codes D007 and D011 (due to toxic levels of chromium and silver, respectively).
Looking at the 172.101 table (the hazardous materials table at 49 CFR 172.101) we can ship using IP3 = flexible IBC must be sift-proof and water-resistant. (IP3 is a special provision code found in column 7 of the hazardous materials table).
I think that is all we need. They do not need to be otherwise UN rated sack.
Am I right?
Thanks
Before I could answer he provided more information (12.08.17):
I was just told that since it is a hazardous waste that we should ship as a hazardous waste, not hazardous substance name so we are not allowed IP3 and must follow IB8.
Thoughts?
My answer (12.08.17):
I believe I have an answer to your question below.
I do not believe the HazMat you describe can be classified as UN3077, Environmentally hazardous Substance, Solid, n.o.s. This is because special provisions code 146 in column 7 for that entry reads as follows (emphasis added):
This description may be used for a material that poses a hazard to the environment but does not meet the definition for a hazardous waste or a hazardous substance, as defined in §171.8 of this subchapter, or any hazard class, as defined in part 173 of this subchapter, if it is designated as environmentally hazardous by another Competent Authority. This provision may be used for both domestic and international shipments.
Since this HazMat is a hazardous waste (USEPA hazardous waste codes D007 & D011) and will likely be an reportable quantity (RQ) of a hazardous substance for one or both, it can’t be shipped as UN3077, Environmentally hazardous substance, solid, n.o.s.
Instead, I believe, it must be classified as: NA3077, Hazardous waste, solid, n.o.s., 9, PG III.
Both UN3077 and NA3077 are subject to special provision code IB8 which indicates the need for specification packaging when shipping in an IBC (intermediate bulk container).
UN3077 alone is subject to IP3 which is in addition to IB8 and not a replacement for it.
Both UN3077 and NA3077 are subject to bulk packing instructions at 49 CFR 173.240. While these packing instructions allow for non-DOT specification rail cars (paragraph a), motor vehicles (paragraph b), and portable tanks and closed bulk bins (paragraph c), it requires specification packaging for IBCs (paragraph d).
In short, this HazMat must be classified as NA3077, Hazardous waste, solid, n.o.s., 9, PG III and if shipped in an IBC must be packed in a DOT specification packaging.
I hope this helps. Please contact me with any other questions.
Interested in a Webinar that covers this topic, and more!
Sir, my company routinely ships HazMat totes 275-over 300 gallons that have UN numbered placards on two sides on freight trailers that are placarded that don’t have the UN number, like the kind used for packaged HazMat.
But,,,I remember from HazMat class at previous jobs that if there’s a UN number on the tote, it’s a bulk container and needs bulk placards with that UN number on all four sides of the truck.
Is this correct..?,, because this is the case often in freight companies, even the supervisors don’t know.
They say that no where does it say it’s illegal to use standard placards for bulk container transportation.
Note: An image of an intermediate bulk container (IBC) was included as an attachment to the email. A Class 3 Flammable Liquid placard with the identification number of (UN)1170 was visible on one side.
My reply (March 05, 2018):
Thank you for contacting me. Please see below.
The packaging you describe and the image shown is an intermediate bulk container (IBC).
The Hazardous Materials Regulations allow for many options for the display of labels, placards, and package marks on an IBC of this size. Read: HazMat Labels, Placards, and Marks on an IBC. However, in one form or another the identification number must be displayed on the IBC.
Per 49 CFR 172.331(c) when a bulk packaging like an IBC is contained in or on a transport vehicle the identification number marking on the IBC must be visible or the transport vehicle must be marked with the identification number on each side and each end.
Per 49 CFR 172.332, the identification number mark on a transport vehicle may be displayed in one of three ways:
On the placard (172.332(c)).
On an orange panel near the placard (172.332(b)).
On a white square-on-point near the placard (172.336(b)).
I hope this helps. Please contact me with any other questions.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
Daniel,,,,,,,, Thank You very much for the info. I forwarded this to my terminal manager.
You would be surprised to know how many freight drivers (City and shuttle drivers) do not follow the hazMat regs.
I have worked in fuel and oil jobs in the past. But in many cases Freight Companies hire drivers with zero HazMat experience and the company does not provide any HazMat training.
Well, maybe on paper, but not in actuality.
Conclusion:
Beware the things that “everyone knows to be true” about the Hazardous Materials Regulations (HMR) of USDOT/PHMSA. Sometimes what everybody knows turns out to be wrong. The correct answer can only be found in the HMR. You – or your employees – may contact me directly to get the answers to these questions or you could get your questions answered and fulfill the training requirements of the HMR by attending my HazMat Employee training.
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 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
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):
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:
If you are on holiday I hope your enjoying your 4th of July as well.
I do have one question. Are you familiar with “markings” on ibc one way containers. I call them stringers.
It starts of with the type of container/Y/Date/…….some specs, and date tested.
Then to the far right of container will be a smaller marking from a reputable company that has retested the container.
For example M6148 L 3/15. a “L” or “General Maintenance” and the date of the re-test.
According to what I know, if the original “markings” are not clear or damaged from abuse that makes that container ineligible for haz mat shipping.
BUT…..what if the secondary marking to the right, from a reputable company, is legible showing a current “L” retest that is current (2.5yrs) window…..would that make the container legal for shipping haz mat.
It took awhile, but almost two months later I responded:
I have an answer for you!
First of all, I apologize for my delayed response. I’ve been busy providing Onsite Training and Webinar Training plus performing Consulting Services. Questions like yours I research and reply to when I have the time.
The answer to your question is quite simple:
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:
Answer:
The presence of a marking indicating the date of the last leakproofness test or inspection (name of company performing test or inspection and country where test or inspection took place is not required) does not remove the need for the IBC to be marked with its date of manufacture (month and year).
I hope this answers your question. I have more information I learned during my research that I am willing to share with you.
Once again, I apologize for my tardiness.
Please don’t hesitate to contact me with any questions.
It took him almost a month to respond to all of that information, but when he did it was with more questions!
Daniel,
Thank you.
If I may i have another question.
We have a carrier we like using for hot shots.
We will put 6 totes on his truck. 4 with 1760 ID and 2 with 1824 ID. Both are Corrosive. We offer him placards for both ID’s. He does not have means to attach placards to each side of his flatbed. The sides are no issue. We also load equipment along with totes. He will attach the placards on a 500g empty tank at the rear of his truck and also on the front end of his flatbed. Is this acceptable, or legal? So if you can imagine his flatbed with 6 totes, each tote having ID’s on them, and equipment such as tanks, pumps , etc……his flatbed placarded on each side, but the ends placarded on the tanks.
Thanks again.
My reply:
I will research and get you an answer.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
In the mean time…I wrote the following article for my blog based on the research I performed in answering your earlier question. I hope they provide helpful information.
Finally, a few weeks later – and 3 1/2 months from his first question – I answered his latest query:
I will attempt to answer your question. Please see below:
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.
In sum, it is acceptable if the placards and identification numbers are mounted on the load and not on the vehicle as long as they are visible. Without a picture I cannot be certain but I have a question about the visibility of the placard on the front tote on the flatbed. Is it visible to the front? Is the motive power separate from the trailer, i.e. a tractor/trailer combination? Or, is it a straight truck?
I hope this helps.
If you have a question and want a free answer, don’t hesitate to contact me. It may take me some time but I will respond! If you want an answer faster, you’ll have to pay. My consulting services will give you the answer you need in a timely manner so that you can continue with your business without fear of fines or incidents. Whatever your question may be about the transport of hazardous materials or the management of waste (hazardous, universal, used oil, or non-hazardous), don’t hesitate to contact me.
If you prepare for transportation or transport hazardous materials in an Intermediate Bulk Container (IBC), you may be just as confused as I am (or was!) regarding the proper display of the required hazard communication methods. The answering of customer’s questions and the writing of this article forced me to look hard at the PHMSA/USDOT Hazardous Materials Regulations (HMR) and to arrive at an answer. Five of them, actually. In this article I will identify all of the options available to a shipper of HazMat in IBCs for the display of HazMat labels, markings, and placards. I will do this in three sections:
Dispense some preliminary information necessary for complete understanding.
Identify the applicable regulations and their meaning.
Relying on the preliminary information and referring to the applicable regulations, identify five options for display of the required hazard communication methods on IBCs
At the bottom of this article I have embedded a Power Point presentation which summarizes the information presented and illustrates the five options explained herein. Please refer to it as a complement to this article and not a replacement for it.
Before we Begin:
An IBC is defined at 49 CFR 171.8:
Intermediate bulk container or IBC means a rigid or flexible portable packaging, other than a cylinder or portable tank, which is designed for mechanical handling. Standards for IBCs manufactured in the United States are set forth in subparts N and O of part 178 of this subchapter.
To sum up:
An IBC can take many forms, “…rigid or flexible…”. It could be a plastic bladder in a metal cage mounted to a pallet. It could be a nylon or plastic sack. It could be a metal or plastic rigid packaging.
It is not a cylinder for a compressed gas nor is it a portable tank, which is usually much bigger. Both of which are defined in §171.8.
It is designed to be handled by mechanical equipment and not a person or persons. This eliminates most smaller packagings though the IBC is not specifically defined as a bulk packaging as is a cargo tank or portable tank. As a practical matter, every IBC I have ever encountered has been a bulk packaging. For the purposes of this article, we will assume an IBC to be a bulk packaging.
Standards for IBCs are set forth in subparts N and O of 49 CFR 178. This differentiates an IBC from a large packaging or a flexible bulk container (standards set forth in subparts P/Q and R/S, respectively). This is important since these three different types of packagings may appear very similar.
The average volume of an IBC is 275 – 330 gallons. This is important because many of the requirements for HazMat labels, markings, and placards depend upon the volume of the bulk packaging or IBC.
A Summary of the Applicable Hazard Communication Regulations of 49 CFR 172
Subpart D Marking:
§172.301(a)(1): A non-bulk packaging must display the identification number and proper shipping name. There is no requirement to display this marking more than once. As of January 1, 2017 there is a minimum size requirement for the identification number marking on a non-bulk packaging.
§172.302(a)(1): A bulk packaging with a capacity of ≥3,785 L (1,000 gallons) must display the identification number – not the proper shipping name – on all four sides.
§172.302(a)(2): A bulk packaging with a capacity of <3,785 L (1,000 gallons) must display the identification number on two opposing sides.
§172.336(d): A bulk packaging that displays HazMat labels instead of placards according to §172.514(c), may display the identification number in the same manner as a non-bulk packaging at §172.301(a)(1) instead of the identification number marking as it is normally required to be displayed on a bulk packaging.
§172.332: When required on a bulk packaging, the identification number marking must be displayed with one of the following methods:
On the placard.
On an orange panel near the placard.
On a white square-on-point configuration near the placard.
Subpart E Labeling:
§172.400(a)(1): A non-bulk package must display the applicable HazMat label.
§172.400(a)(2): A bulk packaging with a capacity of <18 m3 (640 ft3) must display the applicable HazMat label unless it is placarded according to subpart F. The requirement to label bulk packagings of this capacity does not apply to a cargo tank, portable tank, or tank car.
§172.406(a)(1)(ii): HazMat label – if displayed – must be on the same surface of the package and near the proper shipping name marking.
§172.406(a)(2): Except as provided in paragraph (e) of this section, use of more than one HazMat label on a package is not required.
§172.406(e): Generally, only one of each different required label must be displayed on a package.
§172.406(e)(6): Duplicate labels must be displayed on at least two sides of an IBC with a capacity of ≥1.8 m3 (64 ft3).
Subpart F Placarding:
§172.504(a): Except as otherwise provided, a bulk packaging containing any hazardous material must display the applicable placard on all four sides.
§172.514(c): An IBC may display placards on two opposing sides or it may display HazMat labels according to subpart E.
§172.514(c)(4): An IBC displaying HazMat labels in accordance with subpart E may display the identification number in the same manner as a non-bulk packaging at §172.301(a)(1) instead of the identification number marking as it is normally required to be displayed on a bulk packaging.
Options for labeling, marking, and placarding Intermediate Bulk Containers
Option 1:
An option available to all bulk packagings – and the most burdensome – is to display placards and identification number on all four sides of the bulk packaging. The identification number must be displayed on or near the placard.
Display placards on all four sides of a bulk packaging per §172.504(a).
The display of the identification number marking on all fours sides is required for a bulk packaging of ≥1,000 gallons at §172.302(a)(1) and is an option for a bulk packaging with a capacity of <1,000 gallons.
Display the identification number marking on or near the placard per §172.332 as for any bulk packaging.
Option 2:
A small revision to option 1 is to display placards on all four sides of the IBC and, if the capacity is below the threshold amount, to display the identification number marking on two opposing sides.
Display placards on all four sides of a bulk packaging per §172.504(a).
Display the identification number marking on two opposing sides per §172.302(a)(2) for a bulk packaging with a capacity of <1,000 gallons.
Display the identification number marking on or near the placard per §172.332 as for any bulk packaging.
Option 3:
Both option 1 and 2 are available for most bulk packagings. With option 3 we arrive at one specifically designed to ease the regulatory burden for those who ship HazMat in IBCs. Option 3 allows for the display of placards on two opposing sides of the IBC along with the identification number marking if the capacity of the IBC is below the threshold amount.
Display placards on two opposing sides of the IBC per §172.514(c).
Display the identification number marking on two opposing sides per §172.302(a)(2) for a bulk packaging with a capacity of <1,000 gallons.
Display the identification number marking on or near the placard per §172.332 as for any bulk packaging.
Option 4:
Option 4 continues the progression of relaxing the regulatory responsibilities specifically for the use of IBCs as a packaging for HazMat. Option 4 allows for the display of HazMat labels on two opposing sides of an IBC with a capacity of ≥1.8 m3 (64 ft3). If taking advantage of this option the shipper may also display the proper shipping name and identification number marking near the HazMat label on one side of the IBC in the same manner as if it was a non-bulk packaging.
For a bulk packaging with a capacity of <18 m3 (640 ft3), either display HazMat labels or placards according to subpart F per §172.400(a)(2).
Display HazMat labels on the IBC as directed by subpart E per §172.514(c).
According to §172.406(a)(2) and §172.406(e), display of more than one HazMat label on a package is not required.
Display HazMat labels on two opposing sides of an IBC with a capacity of ≥1.8 m3 (64 ft3) per §172.406(e)(6).
Display the proper shipping name and identification number marking in the same manner as a non-bulk packaging as is described at §172.301(a)(1) per §172.514(c)(4).
Option 5:
I saved the best option for last. A shipper of hazardous materials in an IBC may display a HazMat label on one side of an IBC with a capacity of <1.8 m3 (64 ft3). Remember: the capacity of a typical IBC is 275 – 330 gallons (330 gallons = 1.25 m3 = 44 ft3). If taking advantage of this option the shipper may also display the proper shipping name and identification number marking near the HazMat label on one side of the IBC in the same manner as if it was a non-bulk packaging.
For a bulk packaging with a capacity of <18 m3 (640 ft3), either display HazMat labels or placards according to subpart F per §172.400(a)(2).
Display HazMat labels on the IBC as directed by subpart E per §172.514(c).
According to §172.406(a)(2) and §172.406(e), display of more than one HazMat label on a package is generally not required.
Display HazMat labels on one side of an IBC with a capacity of <1.8 m3 (64 ft3) per §172.406(e)(6).
Display the proper shipping name and identification number marking in the same manner as a non-bulk packaging as is described at §172.301(a)(1) per §172.514(c)(4).
If you are uncertain about the option to display the proper shipping name and identification number marking on the IBC per §172.301(a)(1) as if it was a non-bulk packaging, so was I! Please refer to this PHMSA letter of interpretation issued in response to my query (LOI 15-0120) for confirmation that this option complies with the HMR. Please note the reference in the letter to §172.302(b)(2) isn’t an error. That particular citation was removed from the HMR during an update that took place after the date of the letter’s posting. It was replaced with §172.301(a)(1).
Here’s that Power Point embed I referred to at the beginning of this article. Remember, use it as an illustration to further explain the five options explained in this article.
That – I believe – is it. I’ve scoured the Hazardous Materials Regulations and cannot find any other options for the display of HazMat labels, markings, and placards on an Intermediate Bulk Container. Have you? Please let me know if you have, I’d love to add another option to this article. In truth, it’s option 5 that is the most important to shippers of hazardous materials in an IBC: no placards; no identification number marking on an orange panel, or on the placard, or on a white square-on-point; just a HazMat label and proper shipping name and identification number marking displayed on one side just as if it was a non-bulk packaging.
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Interested in more information about shipping HazMat in IBCs?
In an earlier article I identified and explained the requirements of 49 CFR 178.703(a) that mandate the manufacturer of an Intermediate Bulk Container (IBC) mark it with certain letters, numerals, and symbols to indicate that it is specification packaging designed, manufactured and tested to meet a UN standard. But the markings required by paragraph (a) of §178.703 may not always be enough. In paragraph (b) of §178.703 markings are identified that are to be displayed on an IBC, “in addition to markings required in paragraph (a) of this section”.
The purpose of this article is to identify and explain the requirements of 49 CFR 178.703(b) for additional specification packaging markings to be used on intermediate bulk containers. (more…)
