Interpretation Response #16-0017
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
June 02, 2016
LOGSA Packaging, Storage and Containerization Center
11 Hap Arnold Boulevard
Tobyhanna, PA 18466
Reference No. 16-0017
Dear Mr. Gesford:
This letter is in response to your January 13, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to test requirements for Intermediate Bulk Containers (IBC). Specifically, you ask for further clarification of the term “rupture” as used in § 178.819(c) as criteria for an IBC to pass the vibration test. You describe two scenarios and provide accompanying photographs of fiberboard IBCs with damage resulting from the vibration test. The IBC in “Figure 1” shows the inner bag protruding from damage that extends along the full height of the fiberboard outer container. The IBC in “Figure 2” shows a tear—described as approximately 3 inches in height—to the fiberboard in the bottom corner, and while the damage penetrates the outer fiberboard wall, the inner bag is not visible. You further describe that leakage was not observed in either scenario. We have paraphrased and answered your questions as follows:
Q1. Does a rupture to a fiberboard IBC include any damage that results in separation or tearing of the outer fiberboard container which creates an opening?
A1. The answer is yes. Section 178.819(c) states that an IBC passes the vibration test if there is no rupture or leakage. The word “rupture” is defined by Webster’s dictionary as a “state of being broken, the act of bursting.” It is the opinion of this Office that any damage that creates an opening in an IBC would be considered a rupture and result in the failure of the vibration test. The entire side of the IBC in “Figure 1” has burst open, and although the damage to the IBC in “Figure 2” is less severe, the damage has still penetrated the outer fiberboard container, creating an opening. Therefore, the IBCs in both scenarios have failed the vibration test due to rupture.
Q2. Does a rupture to a fiberboard IBC include instances where the inner bag is exposed or protrudes from the box due to damage to the outer fiberboard container, but the inner bag remains intact and does not leak?
A2. The answer is yes. See A1.
Q3. Does a rupture to an IBC include instances of breakage of the IBC closure components, such as tape?
A3. Generally, the answer is yes. Typically, breakage of an IBC closure component is expected to result in failure of the vibration test due to leakage or due to a full or partial opening of the package (i.e. rupture). However, if the IBC remains fully closed and does not leak, then the breakage of an IBC closure component does not result in a failure of the vibration test.
Q4. Can an IBC fail the vibration test based on evaluation for criteria contained in other IBC test requirements, such as “deformation” or “unsafe for transportation,” without the presence of the actual wording in the vibration test criteria in § 178.819? For example, the criteria for a fiberboard IBC to pass the stack test in § 178.815(e)(2), requires “no loss of contents and no permanent deformation, which renders the whole IBC, including the base pallet, unsafe for transportation.”
A4. The answer is no. The vibration test is a pass or fail test determined only by whether the IBC withstands testing without leakage or rupture. The criteria for passing the vibration test in § 178.819(c) was incorporated into the HMR by a final rule entitled, “Intermediate Bulk Containers for Hazardous Materials (HM-181E),” published July 26, 1994. This requirement is generally harmonized with the United Nations Manual of Tests and Criteria, which specifies in 184.108.40.206.4, “No leakage or rupture shall be observed. In addition, no breakage or failure of structural components, such as broken welds or failed fastenings, shall be observed.” It should be noted that the safety of a packaging for transportation depends on the cumulative effects of all packaging design, testing, and use requirements in the HMR. In addition to the vibration test, the IBC must meet all applicable design requirements in Part 178 Subpart N and all applicable test requirements in Part 178 Subpart O to be certified for transportation.
I hope this information is helpful. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
178.819(c), 178.819, 178.815(e)(2), 178.819(c)
|§ 178.815||Stacking test|