IBC handling hazardous materials have an inspection frequency

Intermediate Bulk Containers (IBC) have become very popular in various industries.  They have also become a major pain in the _ss for many safety and process safety professionals as they have become a “catch-all” type of container.  This week, we encountered an IBC permanently implemented as a “process vessel” within a PSM/RMP-covered process.  And as you can imagine, it was not in the PSI, SOPs, or MI program.  So I thought it might be fitting to mention how these containers must be managed and to say it very clearly… IBCs are NOT intended to be used as a process vessel!

DOT requires that each IBC used to transport liquid hazardous materials (or discharge solids under pressure) be tested and inspected every 2.5
years starting from the date of manufacture or the date of a repair.  The requirements are:

1. Performance of a leakproofness test
2. EXTERNAL VISUAL INSPECTION (bottle removed from the cage) to ensure:
   1. The IBC is marked properly. Missing or damaged marks or marks that are difficult to read must be restored or returned to original condition.
   2. Service equipment is fully functional and free from damage that may cause failure. Missing, broken, or damaged parts must be repaired or replaced.
   3. The IBC is capable of withstanding the applicable design qualification tests.
   4. There are no cracks, warpage, corrosion or any other damage which might render the IBC unsafe for transportation. An IBC found
      with such defects must be removed from service or repaired.
3. EVERY FIVE (5) YEARS from the date of original manufacture the IBC inner receptacle must be INTERNALLY INSPECTED to ensure that the IBC is free from damage (e.g. cracks, warpage) and to ensure that the IBC is capable of withstanding the applicable design qualification tests.

I know from experience that many totes find their way to becoming “scrubber vessels” for unloading transportation containers into fixed-bulk containers at facilities.  PSM or not, if the HAZMAT needs a scrubber of sorts, then the IBC used as such MUST be in some type of engineering/hazard evaluation for the use and in a Preventive Maintenance program to ensure its continued SAFE use.

Source: 49 CFR §180.352