MDI Transportation Guidelines - Polyurethanes - American ...

MDI transportation
g u i d e l i n e s
• Stacking;
• Leakproofness (liquids only);
• Hydrostatic (liquids only), and
• Drop tests.
Each container must be visually inspected, tested for leakproofness, and marked with the retest date
(if used for transporting liquids) every 2.5 years from the date of manufacture (49 CFR §180.352).
4.3.3 Record keeping
The person certifying the testing of an IBC in Hazardous Materials service must keep records of periodic
retests and initial and periodic inspections. Records must include:
• Design types and packaging specifications;
• Test and inspection dates;
• Name and address of test and inspection facilities;
• Names of persons conducting tests or inspections; and
• Test or inspection specifics and results.
Records must be signed by the person conducting the test and must be kept for each packaging at
each location where periodic tests are conducted. These records must be kept until such tests are
successfully performed again or for 2.5 years from the date of the last test.
4.4 Drums
MDI is not classified as a hazardous material by the DOT if shipped in a single container in quantities less
than 5,000 pounds. Thus, MDI is not regulated in drums. However, in accordance with their commitments to
Responsible Care ® , MDI producers typically ship MDI in packaging that satisfies stringent DOT performance
tests designed to ensure that packaging integrity will be maintained.
[Although drum shipments of MDI are not regulated by the DOT, producers generally voluntarily comply with the relevant
modal transport regulations for road (49 CFR), rail (49 CFR), air (49 CFR or ICAO/IATA), sea (IMDG) or inland
waterway (33 CFR). The producers recommend that drums be constructed in conformance with the standards
applicable for the particular material of construction (i.e., steel, plastic, and fiberboard). See 49 CFR § 178.505-509.]
[Additionally, the producers recommend that drums must meet the performance tests prescribed in the regulations.
See 49 CFR §§ 178.600-178.608. See Appendix 5. These regulations also include a provision that the
drums bear certification marks indicating compliance with the UN performance oriented packaging standards
to the appropriate product density and hazard level. 49 CFR § 178.503.]
4.4.1 Drum Specifications
Materials of construction of the drum and all fittings and gaskets must be compatible with the product.
49 CFR § 173.24(e). Drums must be inspected for integrity, tightness, dryness, cleanliness and
absence of rust or foreign particles before filling. See 49 CFR § 173.22(a)(2). Additionally, all diisocyanate
producers agree that open head type drums should not be used for PMDI products due to the
potential for leakage and/or contamination.
Copyright 2001, American Plastics Council
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