The Research and Special Programs Administration wants to consolidate and standardize all existing exemptions that authorize the discharge of intermediate bulk containers from a motor vehicle without removing the IBC from the vehicle.
In many instances, delivery and transfer of small quantities of hazardous materials is safer when done with IBCs rather than drums. However, many sites don’t have the capability to safely unload an IBC from the vehicle before discharging its contents. Based on input from companies that hold one or more of several currently available exemptions, RSPA has proposed a single standardized exemption that would require all involved parties to operate under the same provisions and controls.
Packaging would have to meet DOT specifications and carriers would be required to implement operational controls covering equipment and procedures. For instance, the IBC would have to be attended by a qualified person at all times during unloading. The discharge system would have to be inspected before starting the transfer then cleaned and inspected before refilling.