Regulatory Helpdesk: July 30

IBC Residue, Choosing Placards, IATA Special Provisions, and Hazard Class Label Size

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations. Please note that over the summer we will be going to a bi-weekly posting of Regulatory Helpdesk.

Residue in IBCs (TDG)

Q. Under TDG, do Intermediate Bulk Containers (IBCs) such as tote tanks that contain residues still have to be transported as dangerous goods? Should the placards remain or be removed?
A. Under TDG, packagings or containers that still contain enough residue to pose a hazard during transportation should still be treated as dangerous goods. Unfortunately, the regulations do not give a specific way of judging this, so they should be considered hazardous unless you are absolutely sure they are not. (There is some misinformation that you may come across about how to make this decision. TDG does not specify “triple-rinsing” as a standard for cleaning or declare that an inch or less of residue can be considered non-dangerous. These references may come from other regulations or industry guidelines, but do not apply to TDG.)

So, if your IBC contains a dangerous residue, it should be clearly identified as such for transportation. If it was originally placarded or labelled correctly, just leave those safety marks visible. If they have been damaged, removed or become illegible, you’ll have to replace them before transport. IBCs do not have to be marked with the word “Residue,” just the dangerous goods safety marks they had when they were full.

Adding the words “Residue – last contained” to the shipping description on the shipping document is optional as long as there is less than 10% of the original contents in the IBC.

Note that residue drums get an exemption which cannot be used for IBCs. This exemption, found in section 1.44, allows the carrier to pick up residue drums as long as they are accompanied by a document (which can be provided by the shipper or the carrier) that lists the number of drums of each class, such as “4 Class 3 Residue Drums.” In this case, the shipper is required to provide “DANGER” placards if offering more than ten drums in one shipment. However, this exemption specifies that it is for drums only and cannot be used for other means of containment.

Which Placards for My Shipment? (49 CFR)

Q. Can you help me determine which placards I need for my products? I understand much depends on my package size, the tables in §172.504 of 49 CFR and the weights of my materials. Just looking for some general guidance.
A. All of my guidance is based on the hazardous materials table in §172.101 of 49 CFR. If you have test data on a product that proves your material does not meet the hazard class listed then please default to the Special Provisions and allowances in §175.504. Your UN2531 would be a class 8 corrosive. For UN1247 must be flammable liquid not the combustible one you initially believed it to be. The table calls it a Class 3 in Packing Group II. Now, UN2283 is normally a flammable liquid in Packing Group III. It could be RECLASSIFIED as Combustible if the flashpoint is above 38°C (100°F) but below 60°C (140°F). If that is the case, then combustible liquids depending on their package size does have some exceptions for identification and placarding. The UN2277 must be flammable liquid. As to your UN2929, you have 2 hazard classes assigned. The primary is a 6.1 and the secondary is a 3. Keep in mind placards are based on primary hazards only unless there is a subsidiary hazard of 2.3 or 6.1 Inhalation Hazards or 4.3 Dangerous When Wet. Your material would be placarded for just the 6.1

IATA Special Provision A197

Q. Can you explain IATA’s Special Provision A197 to me? I have UN3082 inside 2 containers that are 3 liters each. They are part of a combination package. Do I have to use the marine pollutant mark on the outside of the box?
A. SP A197 can be tricky to comprehend. This particular special provision is telling you that as long as all the inner containers have 5 Liters or less of UN3082 in them, then you can put as many of them as you like in the outer container and it will not be regulated.

Reduced Size Hazard Class Labels

Q. Regarding the class label Size -Permission to reduce size for small container,As per Section 4.7, the labels can be reduced to 30 mm on each side (usually 100mm). For example, the label for 20 kg chlorine pucks (UN2468, Class 5.1, PGII) size reduced to 60 mm each side. Could you please confirm if my understanding is correct?
A. You are correct.

TDG §4.7(2) says:

Each side of a label must be at least 100 mm in length with a line running 5 mm inside the edge. However, except for dangerous goods included in Class 7, Radioactive Materials, if that size label, together with the shipping name, technical name, and UN number, cannot be displayed because of the irregular shape or size of the small means of containment, each side of the label may be reduced in length by the same amount to the point where the label, together with the shipping name, technical name, and UN number, will fit that small means of containment, but must not be reduced to less than 30 mm.

Note that there are certain restrictions on using this section to reduce the size of the label.

  1. It must be because a full-sized 100 mm per side label will not fit or attach onto the container. (For example, neck labels on cylinders won’t fit at normal size, so they can be reduced.)
  2. The label can’t be reduced below 30 mm per side.
  3. This doesn’t apply to Class 7 (Radioactive) labels, which must always be at 100 mm.

Also, this provision does not apply for air shipment. Under the IATA Dangerous Goods Regulations, most class and handling labels cannot be reduced (although there are some exceptions for Class 2 and Division 6.2 labels, as well as the lithium battery handling mark).

Karrie Ishmael

Karrie Ishmael

Karrie started with the company in 1988 and has worked in a variety of capacities including customer service, sales, management, and marketing. In her current role as Regulatory Manager, she manages and supports ICC's efforts in supplying value-added services including training and SDS services to our clients. She is knowledgeable in a variety of regulations. She actively participates in a multitude of associations including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.