There’s a broken plastic fitting on a pump mounted to the top neck fill on an intermediate bulk container (IBC), but the opening is located at 6 inches or more above the fluid level of the package. Also, there’s a little discharge but no continued leakage. Did you pass the IBC drop test for transporting hazardous materials?
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Well, no!
The Pipeline and Hazardous Materials Safety Administration (PHMSA) has testing requirements for various packaging scenarios. One of these tests is the drop test, i.e., would the package and materials inside maintain their integrity if dropped from certain heights. Today we will discuss the general drop test requirements for IBCs.
Who—Me?
As discussed in yesterday’s Advisor concerning drop test requirements for nonbulk packages/packagings, it is the responsibility of the packaging manufacturer to assure that each package can pass the required tests, including the drop test. However, a package assembly function, including final closure, is performed by the person who offers a hazardous material for transportation (the shipper or offeror). The offeror must determine that the packaging or container is an authorized packaging, and that it has been manufactured, assembled, and marked in accordance with, in part, all the testing requirements.
When You Drop an IBC
IBCs are rigid or flexible portable packagings, other than a cylinder or portable tank, that are designed for mechanical handling.
How to Prepare for the Drop
For IBCs, there are four specific drop test preparation requirements, found at 49 CFR 178.810, depending on the makeup of the IBC and its contents.
- Metal, rigid plastic, and composite IBCs intended to contain solids must be filled to at least 95% of their maximum capacity, or if intended to contain liquids, to at least 98% of their maximum capacity. Pressure relief devices must be removed, and their apertures plugged or rendered inoperative.
- Fiberboard and wooden IBCs must be filled with a solid material to at least 95% of their maximum capacity. The contents must be evenly distributed.
- Flexible IBCs must be filled to the maximum permissible gross mass. The contents must be evenly distributed.
- Drop tests for rigid plastic IBCs and composite IBCs with plastic inner receptacles must be carried out when the temperature of the test sample and its contents has been reduced to −18°C (0°F) or lower. Test liquids must be kept in the liquid state. If need be, you can add antifreeze.
In addition to the specific requirements for drop testing, fiberboard IBCs and composite IBCs with fiberboard outer packagings must be conditioned for at least 24 hours in an atmosphere maintained at 50% ±2% relative humidity and at a temperature of 73°F ±4°F; or at 65% ±2% relative humidity and at a temperature of 68°F ±4°F.
The target that a package is dropped to must be hard and flat. The point of impact must be the most vulnerable part of the base of the IBC being tested. Following the drop, the IBC must be restored to the upright position for observation. The drop height depends on the packing group of the material and whether, if a liquid, the test is performed with water. In every case, the height is highest (up to 5.9 feet) for materials in Packing Group 1, which is the packing group for the most hazardous materials.
Note: An additional drop test must be performed for IBC design types with a capacity of 15.9 cubic feet or less.
Did You Pass the Drop Test?
To pass the IBC drop test:
- There may be no damage that renders the IBC unsafe to be transported for salvage or for disposal.
- There may be no loss of contents.
- The IBC must be capable of being lifted by an appropriate means until clear of the floor for 5 minutes.
- A slight discharge from a closure upon impact is not considered to be a failure of the IBC provided there is no further leakage.
- A slight discharge (e.g., from closures or stitch holes) upon impact is not considered a failure of the flexible IBC provided there is no further leakage after the IBC has been raised clear of the ground.
Scenario
A company asked if an IBC passed the drop test in the following scenario. The IBC ends up with a broken plastic fitting on a pump mounted to the top neck fill, but the opening is located at 6 inches or more above the fluid level of the package, and there’s a little discharge, but no continued leakage.
According to PHMSA officials, this IBC failed the drop test. They point to the IBC drop test requirement that “there may be no damage which renders the IBC unsafe to be transported for salvage or for disposable.” PHMSA’s reasoning is that a damaged fitting that creates an opening in the package renders the IBC unsafe to be transported.