Ccsb Docket 2019-2 Section I

CCSB DOCKET 2019-2 SECTION I

SUBJECT 13 Re: Items (Rules) 203 and 280 — Intermediate Bulk Containers (IBCs)

CCSB Contact: Erin N. Topper Telephone — (703) 838-8856 [email protected]

Proponent: Classification Resource Committee

Proposed Classification Provisions

It is proposed to cancel Item (Rule) 203 with reference to Item (Rule) 280, and concurrently amend Item 280, as follows:

ITEM 203

DEFINITION AND SPECIFICATIONS FOR PLASTIC SEMI-BULK BAGS

Cancel; see Item 280.

ITEM 280

DEFINITION OF OR SPECIFICATIONS FOR INTERMEDIATE BULK CONTAINERS (IBCs)

General Definition and Specifications Sec. 1. Intermediate Bulk Containers (IBCs) are large flexible, semi-rigid or rigid portable packages that permit handling with mechanical equipment and may be constructed from a variety of materials including fabric, fiberboard, metal, plastic or wood, or a combination thereof, see Secs. 2 and 3 herein. The receptacle of an IBC has a volumetric capacity of not more than 3,000 liters (793 gallons or 106 cubic feet) and not less than 450 liters (119 gallons or 15.9 cubic feet) or a maximum net mass of not less than 400 kilograms (882 pounds). They must be designed with handles, straps, legs, an integral lift truck skid, pallet or platform base, or be secured on a lift truck skid, pallet or platform so as to provide for mechanical equipment to safely pick up the container, and must be constructed so as to sufficiently contain and protect the contents and withstand the normal rigors of the less-than-truckload environment. IBCs intended for stacking must have an integral stacking alignment or securing design feature. IBCs must be securely closed, and sufficient outage must be left within the IBC to ensure that the package will not leak or be permanently distorted as a result of liquid expansion due to change in temperatures likely to be encountered during transportation. IBCs designed for the transport of solid materials must be sift-proof and water-resistant. Bottom valves must be secured in the closed position, have a secondary means of sealing and must sufficiently protect against damage (e.g. shearing).

Flexible IBCs (FIBCs) Sec. 2. Flexible IBCs (FIBCs) may be used for dry commodities only and must be constructed as follows and meet the performance requirements specified herein. FIBCs must be made from coated or uncoated polyethylene or polypropylene woven fabric so constructed as to contain and protect the contents and withstand the normal rigors of the less-than-truckload environment. Handles or straps must harness, encircle or be securely attached to the FIBC body to facilitate handling by mechanical equipment. FIBCs with spouts for discharging purposes, or with top or bottom filling or discharging openings, must be

SUBJECT 13 Proposed Classification Provisions — Concluded secured by means that will provide a sift-proof closure. FIBCs on lift truck skids, pallets or platforms must be designed and secured so that container and contents will not overhang the lift truck skid, pallet or platform deck. FIBCs may be used again in transportation only when they are in such condition that they will protect contents as effectively as new containers.

Nonhazardous Liquids in Fiberboard IBCs with Inner Plastic Film Bag or Liner Sec. 3. Nonhazardous liquids may be shipped in fiberboard IBCs having an inner plastic film bag or liner and secured on a lift truck skid, pallet or platform. Container must be six-sided and made of solid or of multiwall corrugated fiberboard sufficient to support the capacity of the inner plastic film bag or liner and its contents. Inner plastic film bag or liner must have sufficient outage to provide adequate containment during transport. Fiberboard container must not overhang the lift truck skid, pallet or platform deck and must be secured on the lift truck skid, pallet or platform by strapping in opposing directions, with at least two straps in each direction.

Use for Hazardous Materials Sec. 4. IBCs used for the transportation of hazardous materials must be in conformance with the applicable requirements of Title 49 of the Code of Federal Regulations (CFR). ASTM D7387, Standard Test Method for Vibration Testing of Intermediate Bulk Containers (IBCs) Used for Shipping Liquid Hazardous Materials (Dangerous Goods), may be used to test the integrity of the IBC, providing the 49 CFR requirements have been met.

Analysis

This proposal was docketed by the Classification Resource Committee (CRC) based on a recommendation from the CRC Packaging Subcommittee as a result of reports regarding various issues with intermediate bulk containers (IBCs), and specifically, flexible IBCs (FIBCs) and fiberboard IBCs that contain liquid in a plastic film bag or liner. Recent questions about the general specifications also prompted a review of Item (Rule) 280. Finally, it was brought to the CCSB’s attention that Item (Rule) 203 currently provides specifications for plastic semi-bulk bags, which today would be described as a FIBC.

The proposed Sec. 1 of the rule provides the general requirements and specifications for all types of IBCs. This section of the rule is being updated for clarification and to ensure the IBCs are able to withstand the normal rigors of the less-than-truckload environment. The proposed Sec. 4 of the rule is the current language regarding the shipment of hazardous materials in IBCs.

FIBCs are large bags that are used to transport dry, solid products. This proposal would add a new section to Item 280—Sec. 2—part of which is based on Item 203, as well as Internet research. Although the examples on the following page show FIBCs tendered on lift truck skids or pallets, it is not a requirement, as they may also be forklift handled by means of handles or straps.

SUBJECT 13

A second new section—Sec. 3—would be added to Item 280 to provide specifications for fiberboard IBCs with inner plastic film bags or liners containing nonhazardous liquid products. These specifications were developed to address failures reported for this type of handling unit, as shown in the photo on the right.

Relationship to CCSB Policies and Guidelines

CCSB policies state that packaging rules and specifications are to be established and maintained as necessary to ensure that freight is adequately protected and can be handled and stowed in a manner that is reasonably safe and practicable so as to withstand the normal rigors of the less-than-truckload environment. Furthermore, CCSB policies state that the rules published in the NMFC are to be clear as to intent and otherwise up-to-date. Canceling Item 203 with reference to Item 280, while concurrently amending Item 280, as proposed, is in keeping with CCSB policies.