Interpretation Response #21-0096
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
December 16, 2021
Imperative Chemical Partners
5014 Ashton Audrey
San Antonio, TX. 78249
Reference No. 21-0096
Dear Mr. Melson:
This letter is in response to your September 16, 2021, email and subsequent phone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the orientation of intermediate bulk containers (IBCs) loaded on a motor vehicle and to the hazard label visibility. Specifically, you describe loading IBCs containing flammable, combustible, or corrosive material onto a highway motor vehicle. The vehicle bears the required placards for the commodity in the IBCs on each side and each end of the vehicle. The IBCs themselves are labeled on two opposing sides, rather than bearing placards, and are marked in accordance with § 172.301(a).
Further, you describe and provide diagrams for two loading orientations. In both orientations, the valve of each IBC faces the valve of an adjacent IBC and one label on each IBC and the UN identification (ID) number and proper shipping name marking required by § 172.301(a) directly faces the side of another IBC.
We have paraphrased and answered your questions as follows:
Q1. You ask if the HMR prohibits IBCs from being loading into a transport vehicle with their valves facing "inwards," toward other IBC valves.
A1. The answer is no. In accordance with § 177.834(a), packages having valves or other fittings must be loaded in a manner to minimize the likelihood of damage during transportation.
Q2. You ask if it is permissible for the UN ID number and proper shipping name markings required by § 172.301(a) to face "inwards," toward another IBC in the same direction as the IBC valves.
A2. The answer is yes. Provided the marking is unobscured by labels or attachments, the HMR do not prohibit the UN ID number and proper shipping name markings required by § 172.301(a) from facing other packages when loaded onto a motor vehicle.
Q3. You ask if it is permissible for the hazard label to face "inwards," toward another IBC in the same direction as the IBC valves.
A3. The answer is yes. Provided the label is unobscured by markings or attachments, the HMR do not prohibit the hazard label from facing other packages when loaded onto a motor vehicle.
Q4. You ask if the HMR prohibit the IBC specification markings required by § 178.703 from being loaded in an orientation that is not visible from the outside of the motor vehicle.
A4. The answer is no. The HMR do not require packages to be loaded onto or into a motor vehicle and oriented in a manner such that the packaging specification marking(s) are visible from outside of a motor vehicle.
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
172.301(a), 178.703, 177.834(a)