Reusable Industrial
Packaging Association
RIPA IBC Compliance Workshop
Grand Hyatt Tampa Bay
Tampa, Florida
March 6, 2013
RIPA IBC Compliance Workshop
Introduction

Focus is on composite IBC regulations and compliance. Also
adding (time permitting)  How to be ready for a DOT inspection
 IBCs used for pesticides – EPA activities

Presenters:
 Brian Evoy, Fiber Drum Sales, Inc.
 Wes Ledbetter, Indianapolis Drum Service
 Spencer Walker, National Container Group
 Paul Rankin, RIPA President
 Larry Bierlein, RIPA General Counsel
RIPA IBC Compliance Workshop
Disclaimer
The RIPA IBC Compliance Manual is
comprehensive; however, it is not
intended to be used as a substitute
for the regulations.
RIPA IBC Compliance Workshop
DEFINITIONS & TERMS
US Department of Transportation (DOT)
- Pipeline and Hazardous Materials Safety
Administration, and
- Office Of Hazardous Materials Safety
RIPA IBC Compliance Workshop
DEFINITIONS & TERMS

Intermediate bulk container (IBC).

A rigid or flexible portable packaging, other than a
cylinder or portable tank, which is designed for
mechanical handling. The capacity of the
container ranges from >450 L to 3000 L. Most are
275 – 330 gallons.
RIPA IBC Compliance Workshop
IMPORTANT DEFINITIONS FOR
IBC REPROCESSORS
RIPA IBC Compliance Workshop
DID YOU SAY “IBC REPROCESSOR?”
YES!
DOT does not use the term “reconditioning”
for IBCs. IBCs are “routinely maintained,”
“repaired” or “remanufactured.”
RIPA IBC Compliance Workshop
Routine maintenance (180.350)
A routinely maintained IBC is one that is:


cleaned, with closures reinstalled or replaced in
conformance with the original manufacturer’s
specifications.
OR
which has its structural equipment restored.
RIPA IBC Compliance Workshop
KEY TERMS
Original manufacturer’s specifications
Not defined; generally same style of valve (e.g. ball)
Structural equipment (178.700)
Reinforcing, fastening, handling, protective or stabilizing
members of the body or stacking load bearing structural
members (such as metal cages)
Service equipment (178.700)
Filling and discharge, pressure relief, safety and heating
devices
RIPA IBC Compliance Workshop
Repaired IBC (49 CFR 180.350).
A metal, rigid plastic or composite IBC that is
restored so as to conform to the design type
and is able to withstand the design type tests.
IMPORTANT: The inner receptacle of a
repaired IBC may be replaced [only] with
another inner receptacle of the same design
from the original manufacturer.
RIPA IBC Compliance Workshop
Key Terms
IBC design type (178.801):
An IBC that does not differ in structural design, size,
material of construction, wall thickness, manner of
construction and representative service equipment
Notes: (1) DOT authorizes 25% size reduction for IBC design tests.
(2) Corner protectors are part of design type
Service equipment (178.700):
Filling and discharge, pressure relief, safety and heating
devices
RIPA IBC Compliance Workshop
Remanufactured IBC (180.350).
(This process is commonly called “cross-bottling.”)

A metal, rigid plastic or composite IBC that:
Has an inner receptacle produced by one
manufacturer that is placed into a cage
produced by another manufacturer (or vice
versa), i.e. cross bottling.
RIPA IBC Compliance Workshop
Empty IBC Rule
and
Transportation Requirements
RIPA IBC Compliance Workshop
Empty IBC Requirements

An IBC that has been emptied by a customer is not
absolutely empty; it still holds hazmat residue.

Two federal agencies regulate empty IBC transport  EPA limits the amount of hazmat residue in the
container
 DOT rules govern actual transportation
RIPA IBC Compliance Workshop
EMPTY IBC REQUIREMENTS
EPA rule (261.7)


All residues must be removed that can be
removed (by the emptier!)
OR
0.3% by weight (about 0.8 gal. for 275 gallon
unit)
RIPA IBC Compliance Workshop
Both IBCs are “Empty”
No liquid
0.8 gallon
RIPA IBC Compliance Workshop
DOT REQUIREMENTS FOR TRANSPORTATION
OF EMPTY IBCs
(Shipper/Emptier Requirement)
Openings closed (e.g. cap, valve)
 Labels in place
 Truck is placarded (four-digit
UN ID for each material)
 Shipping papers from emptier
 Driver has hazmat endorsement

RIPA IBC Compliance Workshop
EMPTY IBC CERTIFICATION


RIPA recommends using the RIPA “Empty
IBC Certification” form for every shipment.
Why?



Emptier/shipper must sign and take responsibility
Proof to EPA/DOT that you have done your part
Proof to emptier/shipper if problems arise
RIPA IBC Compliance Workshop
INCOMING IBC ISSUES
RIPA IBC Compliance Workshop
INSPECTION OF NEWLY PURCHASED IBC
BOTTLES
DOT has cited several members for not
testing a new IBC bottle even though the
manufacturer has already done the test and
sealed the bottle.
RIPA IBC Compliance Workshop
INCOMING NEW IBC BOTTLES
When receiving new bottles,
DOT requires performance of a
six-sided visual inspection by a
trained plant employee on each
bottle after it is removed from the
delivery truck.
Purpose: Check for damage
caused in transit that may cause
the bottle to be unusable.
RIPA IBC Compliance Workshop
INCOMING IBC BOTTLE INSPECTION PROCEDURE
1. Inspect ALL incoming bottles on six (6) sides to
damage.
determine
2. Train employees on inspection procedure. This is function
specific training (Keep records in files).
3. Have a letter from each manufacturer stating the bottles
have been properly tested (in manual).
4. Keep record indicating # of remanufactured and repaired
IBCs. (180.352(g))
RIPA IBC Compliance Workshop
Sample Training Document
Incoming IBC Bottle Inspection Procedure
1. Incoming new IBC bottles must be visually inspected on six (6)
sides to determine if any damage that would make the IBC
unusable has occurred during transportation (e.g. cracks,
holes, damaged valve).
2. If any damage to the bottle is detected, the supervisor should
be notified and the bottle should be set aside in a designated
location. No damaged bottles may be used for reprocessing.
3. By signing this training statement, you agree that you
understand the importance of this procedure and how to
conduct incoming bottle inspections.
Supervisors Name
Employees Name
RIPA IBC Compliance Workshop
Incoming “Heavy” IBCs

Emptiers occasionally mistakenly ship IBCs with more
than allowable hazmat residue. Members should have a
written procedure in place to deal with these units.


Some leave “heavy” IBC in truck for immediate
return – shipping paper required.
If unloaded, sequester, rejected sticker, notify
shipper and return. Shipping paper required.
RIPA IBC Compliance Workshop
RIPA IBC Compliance Workshop
HAZMAT SHIPPING PAPERS



Shipping papers (bills of lading) are required
when returning product to an emptier.
Document describes the product and
indicates the hazard.
KEYS: Product Description must match the
Proper Shipping Name in 49 CFR. Original
shipper should provide information.
RIPA IBC Compliance Workshop
HAZMAT SHIPPING PAPERS

Shipping paper (bill of lading) must follow a specific
order:






Proper shipping name
Hazard class
ID number
Packing Group
Reportable Quantity (RQ)
Emergency Response Phone # (24 hour access)
RIPA IBC Compliance Workshop
Example of Proper Shipping Name
(Sulfuric Acid)
UN 1830, Sulfuric Acid, 8, PG III, RQ
Must also include:
- 24 hour emergency response contact
- Shipper’s certification
RIPA IBC Compliance Workshop
IBC TESTING, RETESTING &
RECORDKEEPING
RIPA IBC Compliance Workshop
Leakproofness vs. Leak tightness
“Leakproofness” testing for new, repaired and
remanufactured IBCs (178.813)




Inner receptacle tested without cage
20 kPa air pressure for “suitable time”
Soap solution on seams and joints (or other effective
method)
Pass criteria: No leakage of air from IBC
RIPA IBC Compliance Workshop
IBC Testing, Marking & Recordkeeping

Leak “tightness” testing applies to routine
maintenance


No DOT approved method for conducting this test!
Two common options using air pressure:


Solution over discharge valve for “sufficient” time
Water submersion of discharge valve for “sufficient”
time
Other non-air pressure methods are acceptable
RIPA IBC Compliance Workshop
IBC Retest & Inspection


2.5-years from original manufacture date on the
bottle or last repair:
Must perform:


Leakproofness test and
External inspection (with Bottle Outside the Cage) to
ensure:
 Properly marked
 Service equipment functional
 IBC is “capable” of passing performance tests
RIPA IBC Compliance Workshop
IBC Retest & Inspection

5-year inspection


Leakproofness test
External inspection (bottle outside cage) to
ensure:



Proper marking
Service equipment is functional
IBC is “capable” of passing performance tests
RIPA IBC Compliance Workshop
RECORDKEEPING
Remanufactured IBCs (“cross bottle”)


Maintain a CURRENT copy of design type test
Hold copies for 2.5 years after last sale of any
design type.
NOTE: RIPA MEMBERS DO JOINT TESTING
ANNUALLY ON CERTAIN IBC DESIGNS
RIPA IBC Compliance Workshop
RECORDKEEPING

Retest and inspection records






Description of design types/packaging spec’s
Test and inspection dates
Name and address of facility
Name of person conducting tests/inspections
Results of tests/inspections
Keep test records for 2.5 years AFTER production and
inspection
RIPA IBC Compliance Workshop
IBC MARKING
RIPA IBC Compliance Workshop
RIPA IBC Compliance Workshop
IBC Marking
All marks must be 12 mm high (about ½ inch)

“Primary Mark”
UN 31HA1/Y/11/USA/M 4567/3629/1955

“Additional Mark”
1040L/56kg/100kPa/07 03/07 03
RIPA IBC Compliance Workshop
Bottle Marking

31HA1/M 4567/03 11/USA




IBC design code
Name or symbol of manufacturer
Date of manufacture
Country authorizing mark
PROBLEM: Mark on bottle not always in same place
RIPA IBC Compliance Workshop
IBC Reprocessor Markings

Three types of markings for reconditioners



Routine maintenance
Repair
Remanufacture
RIPA IBC Compliance Workshop
ROUTINE MAINTENANCE
General cleaning; general restoration
Mark: USA/M1234
RIPA IBC Compliance Workshop
REPAIR
General restoration of structural
components/Replacement of inner receptacle
with one from same manufacturer
USA/M1234/03 11
RIPA IBC Compliance Workshop
REMANUFACTURE
“Cross-bottled IBCs”
Bottle from Manufacturer “A” in Cage
Produced by Manufacturer “B”



Design type
Design type test (annual update)
Full mark, just like a “newly” manufactured unit
RIPA IBC Compliance Workshop
Stacking Mark



On all IBCs repaired,
remanufactured, or new
RIPA recommends for
routine maintenance
Lower max kg than new
RIPA IBC Compliance Workshop
What if an original mark is partially
gone or no longer legible?

DOT requires reconditioners to re-apply the
original mark so it is marked in accordance with
requirements in §178.703 of this subchapter.

Missing or damaged markings, or markings
difficult to read must be restored or returned to
original condition.
RIPA IBC Compliance Workshop
Marking is function specific for employee
training programs.
RIPA IBC Compliance Workshop
CLOSURE INSTRUCTIONS
RIPA IBC Compliance Workshop
CLOSURE INSTRUCTIONS


Must be provided to each person to whom a
hazmat packaging is sold.
Instructions must have sufficient detail to
enable proper & consistent closure, including:



Closures used
Closure procedures
Tools needed, etc.
RIPA IBC Compliance Workshop
CLOSURE INSTRUCTIONS

Can be provided electronically (e-mail or
CD); Web not sufficient

RIPA recommends electronic and hard
copy, perhaps with shipping documents
RIPA IBC Compliance Workshop
OTHER MATTERS

Quality assurance program


DOT does not require reconditioners to have an IBC QA
program, but RIPA’s Code of Practice recommends one be
created. Sample in book.
Employee training (initial and every 3 years)



General awareness (includes security training)
Function specific (leak tester/bottle inspection/marking)
Safety
NOTE: SECURITY PLANS ARE NOT REQUIRED