Question (March 03, 2018):

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.

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:

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.

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:

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:

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:

1. Dispense some preliminary information necessary for complete understanding.
2. Identify the applicable regulations and their meaning.
3. 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.

Read here:  What is a bulk packaging?

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).

Conclusion:

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.

[slideshare id=72643433&doc=displayofmarkingsplacardsandhazmatlabelsonibcs-170228013116]

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.

Interested in more information about shipping HazMat in IBCs?

• Requirements for specification packaging markings on an IBC
• Additional specification packaging markings required on an IBC

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.
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