UN standard

Q&A: Can I use a UN Standard IBC for my non-HazMat?

Q&A: Can I use a UN Standard IBC for my non-HazMat?

An email I received 10.21.20:

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.

Specification Packaging Marking on an IBC

  • 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!

My Webinar Training Schedule
My confirmation:

Yup.

Conclusion:

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.

Additional Specification Packaging Markings on Intermediate Bulk Containers of Hazardous Materials

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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The Specification Packaging Marking Requirements of 49 CFR 178.3

Most packagings intended for the transportation in commerce of a hazardous material must be designed, manufactured, and tested to meet either a DOT specification or a UN standard, which is then known as a specification packaging (Don’t confuse “specification packaging” with “DOT specification”, not all “specification packaging” is a “DOT specification” packaging, some may meet a UN standard).  A specification packaging must display a specification marking that meets the requirements of both of the following found in Title 49 of the Code of Federal Regulations:

  • The applicable regulations for the type of packaging; e.g. cylinders, portable tanks, non-bulk, intermediate bulk containers (IBCs), large packagings, and more throughout part 178.
  • The general specification marking requirements for all packagings found at §178.3

In this article I will identify and describe the requirements of 49 CFR 178.3 – specifically, those of §178.3(a) – for the display of the specification marking – either a DOT specification or a UN standard – on a specification packaging.

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