Hazmat Packager and Shipper - Cross Bottling Composite IBCs intended for Hazardous Materials

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Cross Bottling Composite IBCs intended for Hazardous Materials

In the Intermediate Bulk Container (IBC) industry, the practice of cross bottling or re-bottling composite IBCs with rigid plastics inner receptacles purchased from manufacturers other than the original supplier of the receptacle or the outer cage is becoming quite common during the reprocessing of these containers. This practice raises questions and concerns that are currently being reviewed by industry and international and domestic regulatory experts alike. In this report Ms. Hauge looks at the problem of marking these receptacles, packaging integrity, and vibration testing.

In the Intermediate Bulk Container (IBC) industry, the practice of cross bottling or re-bottling composite IBCs with rigid plastics inner receptacles purchased from manufacturers other than the original supplier of the receptacle or the outer cage, is becoming quite common during the reprocessing of these containers. (The composite IBCs in question consist of a rigid plastics inner receptacle, commonly called a bottle, in a metal cage which is then affixed to a pallet.) This practice raises questions and concerns that are currently being reviewed by industry and international and domestic regulatory experts alike.

Under the definition for repaired IBCs, the United Nations Model Regulations for the Transport of Dangerous Goods (UN Orange Book) and the U.S. Department of Transportation’s (DOT) Title 49 Code of Federal Regulations (CFR) both state that the replacement of the rigid inner receptacle of a composite IBC with a receptacle conforming to the original manufacturer’s specification, is considered a repair. The UN Orange Book and DOT 49 CFR both state that a repaired IBC shall be subjected to an inspection to confirm that (1) the IBC conforms to the design type, (2) the internal and external conditions of the IBC are satisfactory, and (3) the service equipment is functioning properly. If the IBC is intended for solids discharged under pressure, or will be used to transport a liquid, the packaging must also be subjected to a leakproofness test. Additionally, DOT 49 CFR states the repaired IBC must be capable of withstanding the applicable design qualification tests.

Upon successful completion of design qualification testing, composite IBCs are required to be marked with the corresponding primary UN marking on the outermost metal cage In addition, and dependent upon the specific design and intended use, the inner receptacle must also be marked with, at a minimum, the name and address or symbol of the manufacturer, the date of manufacture and the country authorizing the allocation of the mark. If the IBC is designed to be dismantled for transport when empty, each of the parts intended to be detached must also be marked with the month and year of manufacture and the name or symbol of the manufacturer. Markings may become confusing. A reconditioner often will obtain a previously used composite IBC or IBC component, repair or recondition the container, and then resell it to a new owner. This may, or may not, include replacing the bottle with a bottle manufactured by a company other than the bottle that was originally subjected to design qualification testing. Parties that originally designed, manufactured and tested the IBCs, and whose marks appear on the packaging, have no control over the components used in the repair process.

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