What does 49 CFR 180.352 (Requirements for retest and inspection of IBCs) require?

Short answer

Four things are required for retest and inspection of IBCs:

1. Each IBC must be inspected and tested before being filled and transported.

2. The IBC must be marked with the country, name or symbol of the person performing the tests and inspections, and the date of the tests and inspections.

3. The structural equipment of an IBC may be repaired and returned to service if it conforms to the original design type and is capable of withstanding the applicable design qualification tests.

4. Service equipment may be replaced if the IBC is subjected to the external visual inspection requirements and the proper functioning and leak tightness of the service equipment is verified.

The rule says

"Each IBC constructed in accordance with a UN standard for which a test or inspection specified in paragraphs (b)(1), (b)(2) and (b)(3) of this section is required may not be filled and offered for transportation or transported until the test or inspection has been successfully completed." (49 CFR 180.352(a))

The country in which the tests and inspections were performed; The name or authorized symbol of the person performing the tests and inspections; and The date (month, year) of the tests and inspections — 49 CFR 180.352(d)(4)(A)-(C).

Except for flexible and fiberboard IBCs, the structural equipment of an IBC may be repaired and returned to service provided: The repaired IBC conforms to the original design type and is capable of withstanding the applicable design qualification tests — 49 CFR 180.352(d)(2)(i).

Service equipment may be replaced provided: The IBC is subjected to the external visual inspection requirements as specified in paragraph (b) of this section; and The proper functioning and leak tightness of the service equipment, if applicable, is verified — 49 CFR 180.352(d)(3)(ii)-(iii).

In plain English

The regulation requires that IBCs be thoroughly inspected and tested before being used to transport hazardous materials. This includes checking the structural equipment and service equipment to ensure they are in good working condition. Any repairs or replacements must be done in accordance with the original design type and must be verified to ensure the IBC is safe for use. The regulation also requires that the IBC be marked with the country, name or symbol of the person performing the tests and inspections, and the date of the tests and inspections.

What to do

• Ensure that all IBCs are inspected and tested before being filled and transported.
• Verify that the IBC is marked with the required information, including the country, name or symbol of the person performing the tests and inspections, and the date of the tests and inspections.
• Develop a procedure for repairing and replacing structural and service equipment on IBCs, and ensure that all repairs and replacements are done in accordance with the original design type.
• Train personnel on the proper procedures for inspecting, testing, and maintaining IBCs.