January, 2008

On September 1, 2006, DOT published a notice of proposed Rulemaking under Docket HM-231, a section of which related to a long-standing issue about proper vibration testing of IBCs using a liquid medium. A recent letter of interpretation was issued by DOT, in response to a question about what material must be used for the vibration test. This article discusses this letter, and provides the history behind this issue.

On September 1, 2006, DOT published a notice of proposed Rulemaking under Docket 231, a section of which related to a long-standing issue about proper vibration testing of IBCs using a liquid medium.

A discussion started in the late 1990’s when members of the Rigid Intermediate Bulk Container Association (RIBCA) encountered interpretive difficulties between industry and government officials about the meaning of the IBC vibration test regulation in 49 CFR 178.819. Most interpreted this rule to indicate that if the IBC were to be used for liquids that it must be tested with water, filled per the typical requirement to 98% of volume. Others said that the phrase “filled… as for shipment” in the rule meant that the test needed to include gross mass considerations. If the IBC were used for a liquid material that had a specific gravity greater than 1.2, then it was required to be tested with a higher specific gravity material. Some persons, typically test laboratories were caught in the middle. Questions arose about previously conducted tests and the validity of test reports based on testing with water.

Persons who tested with the specific gravity consideration in mind, typically artificially increased the weight by adding a solid, heavier material to water to achieve the desired gross weight. Some argued that this was unacceptable since water so “treated” would not duplicate the use of a heavier liquid. Discussions ensued about what heavier materials were suitable and available. There was also serious concern that any material chosen should be non-hazardous according to EPA, CPSC, OSHA and DOT for the benefit of the test personnel and their facilities. Industry and government were in a quandary trying to find a reasonable solution.

To its credit, the testing company Ten-E Packaging Services, Inc. approached RIBCA and offered to run a series of tests in coordination with RIBCA members and DOT officials to find the correct answer. RIBCA members agreed to furnish IBCs free of charge and TEN-E offered to do the testing for industry and government at no charge to either party.

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