{"operation":"document","citation":"16-0017","title":"LOGSA Packaging , Storage and Containerization Center — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-06-02","effective_on":null,"summary":"16-0017 response to LOGSA Packaging , Storage and Containerization Center concerning 178.815, 178.819.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/160017.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMaterials Safety\nPipeline and Hazardous\nAdministration\nJUN 0 2 2016\nAndrew Gesford\nChief\nLOGSA Packaging, Storage and Containerization Center\n11 Hap Arnold Boulevard\nTobyhanna, PA 18466\nReference No. 16-0017\nDear Mr. Gesford:\nThis letter is in response to your January 13, 2016, letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to test\nrequirements for Intermediate Bulk Containers (IBC). Specifically, you ask for further\nclarification of the term \"rupture\" as used in § 178.819(c) as criteria for an IBC to pass the\nvibration test. You describe two scenarios and provide accompanying photographs of\nfiberboard IBCs with damage resulting from the vibration test. The IBC in \"Figure 1\" shows\nthe inner bag protruding from damage that extends along the full height of the fiberboard\nouter container. The IBC in \"Figure 2\" shows a tear—-described as approximately 3 inches in\nheight—to the fiberboard in the bottom corner, and while the damage penetrates the outer\nfiberboard wall, the inner bag is not visible. You further describe that leakage was not\nobserved in either scenario. We have paraphrased and answered your questions as follows:\nQ1.\nDoes a rupture to a fiberboard IBC include any damage that results in separation or\ntearing of the outer fiberboard container which creates an opening?\nAl.\nThe answer is yes. Section 178.819(c) states that an IBC passes the vibration test if\nthere is no rupture or leakage. The word \"rupture\" is defined by Webster's dictionary\nas a \"state of being broken, the act of bursting.\" It is the opinion of this Office that\nany damage that creates an opening in an IBC would be considered a rupture and\nresult in the failure of the vibration test. The entire side of the IBC in \"Figure 1\" has\nburst open, and although the damage to the IBC in \"Figure 2\" is less severe, the\ndamage has still penetrated the outer fiberboard container, creating an opening.\nTherefore, the IBCs in both scenarios have failed the vibration test due to rupture.\nQ2.\nDoes a rupture to a fiberboard IBC include instances where the inner bag is exposed or\nprotrudes from the box due to damage to the outer fiberboard container, but the inner\nbag remains intact and does not leak?\n\n<<<PAGE 2>>>\n\nA2. The answer is yes. See Al.\nQ3.\nDoes a rupture to an IBC include instances of breakage. of the IBC closure\ncomponents, such as tape?\nA3.\nGenerally, the answer is yes. Typically, breakage of an IBC closure component is\nexpected to result in failure of the vibration test due to leakage or due to a full or\npartial opening of the package (1.e. rupture). However, if the IBC remains fully closed\nand does not leak, then the breakage of an IBC closure component does not result in a\nfailure of the vibration test.\nQ4.\nCan an IBC fail the vibration test based on evaluation for criteria contained in other\nIBC test requirements, such as \"deformation\" or \"unsafe for transportation,\" without\nthe presence of the actual wording in the vibration test criteria in § 178.819? For\nexample, the criteria for a fiberboard IBC to pass the stack test in § 178.815(e)(2),\nrequires \"no loss of contents and no permanent deformation, which renders the whole\nIBC, including the base pallet, unsafe for transportation.\"\nA4.\nThe answer is no. The vibration test is a pass or fail test determined only by whether\nthe IBC withstands testing without leakage or rupture. The criteria for passing the\nvibration test in § 178.819(c) was incorporated into the HMR by a final rule entitled,\n\"Intermediate Bulk Containers for Hazardous Materials (HM-181E),\" published July\n26, 1994. This requirement is generally harmonized with the United Nations Manual\nof Tests and Criteria, which specifies in 6.5.6.13.4, \"No leakage or rupture shall be\nobserved. In addition, no breakage or failure of structural components, such as broken\nwelds or failed fastenings, shall be observed.\" It should be noted that the safety of a\npackaging for transportation depends on the cumulative effects of all packaging\ndesign, testing, and use requirements in the HMR. In addition to the vibration test, the\nIBC must meet all applicable design requirements in Part 178 Subpart N and all\napplicable test requirements in Part 178 Subpart O to be certified for transportation.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nlenn Foste\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nLehman\n$178.819 (c\nDEPARTMENT OF THE ARMY\nPackageny Specs.\nPACKAGING, STORAGE, AND CONTAINERIZATION CENTER\nUSAMC LOGISTICS SUPPORT ACTIVITY\nTOBYHANNA, PA 18466-5097\n11 HAP ARNOLD BOULEVARD\nATTENTION OF\nREPLY TO\nJanuary 13, 2016\nLogistics Testing and Applications Division\nMr. Charles E. Betts\nDirector, Office of Hazardous Materials Standards\nU.S. DOT/PHMSA (PHH-10)\n1200 New Jersey Avenue\nSE East Building, 2nd Floor\nWashington, DC 20590\nDear Mr. Betts:\nThis letter of inquiry for interpretation is written on behalf of the US Army Materiel Command\n(USAMC) Logistics Support Activity Packaging, Storage, and Containerization Center (LOGSA\nPSCC), Tobyhanna, PA. It is being written for clarification/interpretation of the Title 49 Code of\nFederal Regulations (CFR), Part 178, Subpart O - Testing of intermediate bulk containers (IBCs),\npertaining to the criteria for passing the vibration test, when testing a IBC.\nTitle 49 CFR §178.819(c) describes the criteria for passing the IBC vibration test as \"An IBC\npasses the vibration test if there is no rupture or leakage.\" Without a definitive explanation for\ndetermining a rupture, it is LOGSA PSCC's opinion that a fiberboard IBC may be determined to\nbe a failure based on damage that might be considered typical degradation of the packaging as it\nmoves through the transportation cycle. Please review the following photographs for further\ndiscussion.\nFigure 1. Test damage - full height of IBC\nFigure 2. Test damage - approximately 3\" high\n\n<<<PAGE 4>>>\n\nFigure 1 shows significant damage of the fiberboard that runs the entire height of the IBC. The\ninner bag is exposed and is observed protruding from the box; no leakage is observed. Figure 2\nshows less severe damage of the IBC. The damage is all the way through the fiberboard wall.\nThe inner bag is not visible and no leakage is observed. The damage noted in Figure 2 is\napproximately 3\" in height, and is similar to damage that we've seen in previous fiberboard IBC\nvibration tests.\nDiscussion. Both photographs show damage of some extent. Figure 1 shows significant\ndamage and appears to no longer be safe for transportation. Figure 2 shows minor damage after\nthe test. LOGSA PSCC's opinion is that at this point the IBC (Figure 2) could still be considered\nreasonably safe for transportation. However, based on current wording specified in 178.819 (c),\nCriteria for passing the test, we feel that both of these pictures show the same type of damage of\nthe packagings (albeit to different extents) and, therefore, could potentially be considered failures\nto pass the vibration test. Without clarification of a rupture, damage that might be considered\nexpected or normal degradation and, therefore, still reasonably safe for transportation (Figure 2.),\nwould have to be declared a failure. In addition, there is no mention of evaluating a packaging for\npermanent deformation or transportation safety as described in other IBC tests (i.e., drop, stack,\ntop lift, and bottom lift).\nIt is LOGSA PSCC's opinion that if the regulations contained a definition of a rupture, and\nincluded wording that allowed for evaluating an IBC with regards to safety, permanent deformation,\nvibration test.\npackaging strength, etc., that fiberboard IBCs could be better evaluated for compliance with the\nQuestions:\n1. With regards to a fiberboard IBC, what determines, or defines, a rupture?\na. Any damage that results in separation, or tearing, of the fiberboard container which\ncreates an opening? If not, how do we differentiate between typical damage and\ndamage that results in a failure of the test?\nb. If the inner bag is exposed due to damage to the fiberboard container, but the inner\nbag remains intact and does not leak, is that a failure?\nc. If the damage is such that the inner bag protrudes from the box, but does not leak,\nis that a failure?\nd. Is breakage of the closure components, such as tape, considered a rupture?\n2. Can the IBC be evaluated for safety, permanent deformation, and/or packaging strength\nwithout the presence of the actual wording in the vibration test criteria?\nPoint of contact for this matter is Mr. Andrew Gesford, DSN 795-5967, (570) 615-5967,\nfax (570) 615-7823, or e-mail andrew.gesford.civ@mail.mil. Mailing address is: Chief, LOGSA\nPackaging, Storage, and Containerization Center (AMXLS-PT/Andrew Gesford), 11 Hap Arnold\nBoulevard, Tobyhanna, PA 18466-5097.\nSincerely,\nChief, Logistics Testing and\nApplications Division","truncated":false,"body_characters":9067}