TDI Transportation Guidelines - Polyurethanes - American ...

ALLIANCE FOR THE 

POLYURETHANES 

INDUSTRY 

A BUSINESS UNIT OF THE AMERICAN PLASTICS COUNCIL 

TDI Transportation Guidelines

TDI transportation 

g u i d e l i n e s 

c o n t e n t s 

Chapter 1 Introduction ..................................................................................................................1 

1.1 Purpose ........................................................................................................................1 

1.2 Safe Handling Precautions .............................................................................................1 

1.3 Transport and Distribution Regulations ...........................................................................1 

1.4 Scope ...........................................................................................................................1 

1.5 Exceptions ....................................................................................................................1 

1.6 Use of Guidelines..........................................................................................................1 

1.7 Transport Contracting Responsibility...............................................................................1 

1.8 Evaluation Application...................................................................................................2 

1.9 Interpretation Caveat ....................................................................................................2 

Chapter 2 Properties, Hazards and Safety Information for TDI...........................................................3 

2.1 Product Identification and Exposure Limits .....................................................................3 

2.2 Typical Physical Data .....................................................................................................3 

2.3 Reactivity Data .............................................................................................................3 

2.4 Health Effects — Short Term..........................................................................................4 

2.5 Health Effects — Long Term ..........................................................................................4 

2.6 First Aid Procedures ......................................................................................................5 

2.7 Disposal .......................................................................................................................6 

2.8 Recommended Formulations for Decontaminant Solutions ................................................8 

Chapter 3 Safety Auditing of Tank Truck Carriers and Bulk Tank Operators .........................................9 

3.1 Carrier’s Capability: Assessment and Control ...................................................................9 

3.2 Carrier Safety Audits .....................................................................................................9 

3.3 Carrier Safety Audit Procedure .......................................................................................9 

3.4 Meeting Safety and Regulatory Standards........................................................................9 

3.5 Scope ...........................................................................................................................9 

Chapter 4 Design and Construction of Transportation Equipment.....................................................11 

4.1 Rail Tank Cars (RTCS)...................................................................................................11 

4.2 Cargo Tanks (Tank Trucks) and Inter-Modal Bulk Tank Containers (ISOTainers) .................11 

4.3 Intermediate Bulk Containers (IBCS) ............................................................................12 

4.4 Drums.........................................................................................................................13 

Chapter 5 HAZMAT Training ..........................................................................................................17 

5.1 Training Requirements .................................................................................................17 

5.2 Specific Requirements for TDI ......................................................................................17 

5.3 Driver Criteria for Transporting TDI...............................................................................17 

5.4 Certified Drivers..........................................................................................................18 

Chapter 6 Personal Protective Equipment for Loading or Unloading TDI ...........................................19 

Chapter 7 Loading Operations ......................................................................................................21 

7.1 Compliance with Transport Regulations.........................................................................21 

7.2 CRITERIA for Loading Facilities and Transport Equipment ...............................................21 

7.3 Design and Construction of Transport Equipment ...........................................................21 

7.4 Availability of Written Operating Instructions ...............................................................21 

Copyright 2002, American Plastics Council 

iii



c o n t e n t s 

7.5 Availability of Personal Protective Equipment................................................................21 

7.6 Inspection of the Bulk Transport Equipment..................................................................22 

7.7 Inspection List: Modifications ......................................................................................24 

Chapter 8 Transport of TDI by Rail ................................................................................................25 

8.1 RESPONSIBILITIES of Rail Tank Carrier...........................................................................25 

8.2 Emergency Intevention ................................................................................................25 

8.3 Inter-Modal Movements ...............................................................................................25 

Chapter 9 Transport OF TDI by Road ..............................................................................................27 

9.1 Routing ......................................................................................................................27 

9.2 Safe Parking................................................................................................................27 

9.3 Severe Weather Conditions ...........................................................................................27 

9.4 Delays or Accidents .....................................................................................................28 

9.5 Inspections During Transport........................................................................................28 

Chapter 10 Transport of TDI by Water Vessel .................................................................................29 

10.1 Approved Containers..................................................................................................29 

10.2 Parties Involved ........................................................................................................29 

10.3 Safety Audits ............................................................................................................29 

Chapter 11 Unloading Operations for Tank Trucks and Rail Tank Cars...............................................31 

11.1 Criteria for Discharge Facilities ..................................................................................31 

11.2 Design, Location and Checks ......................................................................................31 

11.3 Criteria for Discharge Hoses .......................................................................................31 

11.4 Operating Procedures.................................................................................................31 

11.5 Protective Equipment for Operators ............................................................................31 

11.6 Inspection of the Bulk Reception Facilities .................................................................31 

Chapter 12 Required Shipping Information for TDI.........................................................................33 

12.1 TDI’S Hazardous Materials Classification......................................................................33 

12.2 Summary of TDI Hazard Information ...........................................................................34 

12.3 Preparedness and Emergency Response .......................................................................35 

12.4 Principles of Emergency Response Scheme ..................................................................35 

12.5 Technical Communications..........................................................................................35 

a p p e n d i c e s 

Appendix 1: Sample Certificate of Receipt ...................................................................................1-1 

Appendix 2: Guidelines for the Unloading of Tank Trucks (A Suggested Checklist) ..........................2-1 

Appendix 3: Guidelines for the Unloading of Rail Tank Cars (A Suggested Checklist) ......................3-1 

Appendix 4: Guidelines for Customer Bulk Storage Facilities (A Suggested Checklist) .....................4-1 

iv Copyright 2002, American Plastics Council



Chapter 1: Introduction 

1.1 Purpose 

These Guidelines have been prepared by the Alliance for the Polyurethanes Industry (API). They are intended 

to summarize both regulatory requirements affecting the transport and distribution of toluene diisocyanate 

(TDI), and relevant industry safety recommendations. 

1.2 Safe Handling Precautions 

Although TDI is a hazardous material, the hazard may be minimized if appropriate precautions are observed. 

Storage and handling of TDI are regulated by the United States Occupational Safety and Health 

Administration (OSHA). The United States Environmental Protection Agency (EPA) regulates the release, 

clean-up, and waste disposal of TDI, and emissions of TDI during transfer, storage, and use. Individual states 

may also have regulations that affect TDI transfer, storage and disposal. 

1.3 Transport and Distribution Regulations 

The transport of TDI is subject to strict regulations within the United States by the Department of 

Transportation (DOT). In addition, export shipments are regulated by various international organizations that 

establish specific transport requirements that must be observed by all parties. 

1.4 Scope 

These Guidelines take into account the transportation of TDI in bulk tank trucks, rail tank cars, intermediate 

bulk containers (IBCs), and drums. They cover most aspects of transport from loading to delivery point. 

Recommendations are denoted by the use of the word “should;” regulatory requirements are indicated by 

use of the word “must.” 

1.5 Exceptions 

These Guidelines do not deal with bulk movement of TDI in ocean chemical tankers or inland waterway barges. 

1.6 Use of Guidelines 

It is API’s goal to promote the safe transportation and distribution of TDI. API encourages the use of these 

Guidelines as a means of achieving this goal. 

1.7 Transport Contracting Responsibility 

When offering TDI for distribution, companies should arrange transport with reputable, experienced carriers, 

to facilitate the safe transport. 


1



1.8 Evaluation Application 

It is the individual responsibility of users of these Guidelines to evaluate and apply them, taking into account 

all specific circumstances of their own situation. 

1.9 Interpretation Caveat 

No part of these Guidelines may be interpreted in a way that would conflict with existing international and/or 

national legislation. Standards may change, and legal provisions always have precedence over any part of 

these Guidelines. Consult with appropriate legal experts to verify applicable requirements. 

2 Copyright 2002, American Plastics Council



Chapter 2: Properties, Hazards and Safety Information for TDI 

2.1 Product Identification and Exposure Limits 

1 Permissible Exposure Limit 

2 Threshold Limit Value (TLV is a registered trademark of ACGIH) 

3 Time Weighted Average (8 hr. TWA) 

4 Short Term Exposure Limit (15 min. STEL) 

5 Intended Change by ACGIH 

2.2 Typical Physical Data 

2.3 Reactivity Data 


CAS No. OSHA PEL 1 ACGIH TLV 2 

Toluene-2,4-diisocyanate 5 584-84-9 0.020 ppm (as ceiling) 0.005ppm (TWA 3 ), 0.020ppm (STEL 4 ), sensitizer 

Toluene-2,6-diisocyanate 5 91-08-7 0.005ppm (TWA 3 ), 0.020ppm (STEL 4 ), sensitizer 

Toluene-2,4/2,6-diisocyanate unspecified isomers 26471-62-5 

Appearance liquid 

Boiling point about 250°C (482°F) 

Color colorless to pale yellow 

Density (pounds/gallon) 10.2 

Freezing point: 2,4 TDI 22°C (72°F) 

Freezing Point: 2,4/2,6 TDI (80:20 mixture) 14°C (53.6°F) 

Odor sharp, pungent 

Odor Threshold 0.2-0.4 ppm 

Solubility in water not soluble; reacts with the evolution of CO2 

Specific gravity 1.22 (77°/77°F) 

Vapor density 6(air=1) 

Vapor pressure 0.016 mm Hg @ 20°C 

Viscosity 3.0(mPa,cps) @ 20°C (68°F) 

Flash Point 135°C (295°F) 

Auto-ignition >600°C 

Explosion limits — Lower 0.9% v/v (118°C) 

Explosion limits — Upper 9.5% v/v 302°F (150°C) 

Thermal degradation >250°C 

Hazardous degradation products CO, CO2, NOx, HCN 

Materials to avoid water, alcohols, amines, acids, bases 

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2.4 Health Effects - Short Term 

Typically, there are four routes of potential exposure: inhalation, skin contact, eye contact and ingestion. 

Inhalation 

Inhalation of TDI vapors may cause irritation of the mucous membranes of the nose, throat or trachea, 

breathlessness, chest discomfort, difficult breathing and reduced pulmonary function. It is important to avoid 

exposure above the TLV to minimize the possibility of respiratory sensitization. 

Tests have shown that the least detectable odor level of TDI is approximately 0.2-0.4ppm. This odor 

threshold is significantly higher than the OSHA Permissible Exposure Limit (PEL) of 0.02 ceiling. If an 

individual can smell TDI, overexposure has most likely occurred. 

Airborne overexposure, well above the PEL, may result additionally in eye irritation, headache, chemical 

bronchitis, asthma-like findings, or pulmonary edema. TDI has also been reported to cause hypersensitivity 

pneumonitis, which is characterized by flu-like symptoms, the onset of which may be delayed. 

Skin Contact 

Skin contact may discolor the skin or cause redness, swelling, blistering and burns. TDI is categorized by 

DOT as a moderate irritant based on a rabbit skin test. Also, skin contact may cause an allergic contact 

dermatitis and may play a role in respiratory sensitization. 

Eye Contact 

Eye contact with TDI may result in conjunctival irritation and corneal opacity. 

Ingestion 

Ingestion is not a normal industrial route of entry unless contaminated food or tobacco products are 

inadvertently ingested. Good hygiene practices do not allow food or tobacco products to be consumed 

during the use of TDI. If TDI is ingested, severe irritation of the mucous membrane of the mouth, esophagus 

and stomach may occur. 

2.5 Health Effects - Long Term 

Inhalation 

Control of TDI exposure to the recommended guidelines (0.005 ppm as Time-Weighted Average, 0.020 ppm 

as Short Term Exposure Limit) is believed to protect against sensitization. However, if an individual has 

become sensitized to TDI, an asthma-like response may then result from very low exposures to TDI (See 

Medical Surveillance section.) 

Animal inhalation toxicology studies demonstrate that TDI is irritating to the respiratory tract at 

concentrations substantially greater than the exposure guideline. A teratology study in rats showed minimal 

fetal and maternal toxicity at 0.5 ppm, with no effects at 0.1 ppm. There were no teratogenic effects 

(malformations) even at the highest exposure tested (0.5 ppm). (1) TDI caused no reproductive toxicity at the 

highest concentration tested in a rat study (0.3 ppm). (2) 

(1) Tyl et al., (1999). Toxicol Sci. 52(2):248-57. 

(2) Tyl et al., (1999). Toxicol Sci. 52(2):258-68. 




Carcinogenicity 

Long-term inhalation studies (i.e., rat, and mouse) reveal no indications of carcinogenic potential; (3) 

intragastric intubation of high and toxic doses of TDI in corn oil led to increased incidents of tumors. (4) Based 

on the oral study, the U.S. National Toxicology Program considers TDI to be an anticipated human 

carcinogen. IARC lists TDI as group 2B (possibly carcinogenic to humans). Industrial experience in humans 

has not shown any link between TDI exposure and cancer development. The inhalation studies in animals are 

more relevant and therefore are probably a more reliable indicator of effects in humans. 

Medical Surveillance 

Post-offer, pre-placement examinations and periodic medical surveillance of employees are essential 

elements in any program designed to ensure the health and safety of those who work with TDI. The postoffer, 

pre-placement examination should include a respiratory health history, a clinical examination, and a 

baseline pulmonary function testing. Where appropriate, regular medical check-ups (including spirometry) 

may aid in the early detection of any respiratory related effects. Individuals with respiratory problems, such 

as asthma or chronic lung disease, may be susceptible to having respiratory problems when exposed to TDI. 

Individual assessments should be made to determine whether an individual can perform his or her job 

without threatening the health or safety of that individual or others. 

Exposure control to prevent sensitization, and medical surveillance to detect sensitization as early as 

possible are believed to be the most important aspects of TDI safe handling. 

2.6 First Aid Procedures 

All employees working in areas where contact with TDI is possible should be thoroughly trained in the 

administration of appropriate first aid procedures. Experience has demonstrated that prompt administration 

of such aid can be important in minimizing the possible adverse effects of accidental exposure. 

Inhalation 

Promptly move the affected person away from the contaminated area to fresh air. Keep the affected person 

calm and warm, but not hot. If breathing is difficult, oxygen may be administered by a qualified person. If 

breathing stops, a qualified individual give artificial respiration and seek medical attention immediately. 

Skin Contact 

In the event of skin contact, wash thoroughly with soap and flowing water for at least fifteen minutes (A 

recent study has indicated that corn oil or polyglycol-based cleaners may remove MDI more effectively than 

soap and water, and this may also apply to TDI. (5) Cleaning soon after contamination was also important.). 

Promptly remove all contaminated clothing (including shoes) while washing. If the skin is burned or irritated, 

seek medical attention. Decontaminate clothing prior to re-use by soaking the garments in an 8 percent 

ammonia solution for one hour prior to laundering with hot water and detergent. Destroy all contaminated 

leather items including shoes, belts, and watchbands. 

(3) Loeser, E. (1983), Toxicology Letters 15:71-81. 

(4) National Toxicology Program (1986) Toxicology and Carcinogenesis Studies of Commercial Grade 2,4 (80%)-and 2,6 (20%)-Toluene 

diisocyanate (CAS No. 26417-62-5) in “F 344/N Rats and B6C3F1 Mice (Gavage Studies),” NTP Technical Report Series No. 251. 

(5) Wester et al. (1999). Toxicol Sci. 1999 Mar;48(1):1-4. 


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Eye Contact 

If liquid TDI comes in contact with the eyes, irrigate immediately and continuously with low-pressure flowing 

water, preferably from an eyewash fountain, remove contact lenses, if present, and continue eye irrigation for 

at least fifteen minutes. Seek medical attention at once. 

Ingestion 

Do not induce vomiting! In the event TDI is ingested, have the affected person drink large amounts (i.e., 2-3 

glasses) of water or milk. Immediately transport to a medical facility and inform medical personnel about the 

nature and extent of the exposure. 

Note to Physician: There is no specific antidote for TDI. Care should be supportive and treatment based 

on the judgment of the physician in response to the reaction of the patient. Post-incident checks are needed. 

2.7 Disposal 

Disposal of Waste TDI 

Waste Toluene Diisocyanate (TDI) is listed as a hazardous waste (U - 223) under 40 CFR § 261.33(f) of EPA’s 

Resource Conservation and Recovery Act (RCRA) regulations and requires special handling for disposal. 

However, the easiest and most convenient way to handle excess TDI is to react it with polyol to produce a 

low-quality foam, which then can be sold or used as a manufactured product. (CAUTION: The TDI/polyol 

reaction is exothermic, which may cause spontaneous combustion.) 

Note: Generators may treat TDI “on site” as long as treatment occurs in tanks and containers which meet 

the accumulation provisions in 40 CFR § 262.34 as well as the unit standards in subparts I and J of § 262.5. 

Thermal treatment such as detonation or open burning, however, are precluded from the exemption. 

Another way to dispose of waste TDI is to react the material with a liquid decontaminant. The waste TDI 

should be added slowly or in increments, under mechanical stirring, to the decontaminant, which should be 

contained in an open-top drum. (Note: Be sure this process is conducted in a well ventilated area or 

outdoors.) Allow the reacted material to stand for 48 hours. Decant the liquid and dispose of both the liquid 

and solid materials as hazardous wastes — that is, in full compliance with all applicable federal, state, and 

local laws and regulations. 

Disposal of Empty Containers 

Briefly, there are three options available for disposing of steel drums which last contained TDI. Disposal must 

be in compliance with all applicable federal, state, and local laws and regulations. 

Steel drums may be sent to: 

• a drum reconditioner for reuse, 

• a scrap metal dealer; or, 

• an approved landfill. 




Regardless of the procedure used, however, all drums should be empty (as defined by RCRA, 40 CFR 

§ 261.7) before they leave the TDI user’s facility. (6) (Note: Drums to be sent to a reconditioner may also need 

to be decontaminated. However, since reconditioners use a variety of different techniques to clean drums 

and to prepare them for reuse, the TDI user should consult with the reconditioner before using any drum 

decontamination procedure.) 

Drums destined for a scrap dealer, an incinerator, or a landfill should be decontaminated, then punctured or 

crushed to prevent reuse. (Note: Empty TDI drums can be decontaminated by filling them with water or a 

decontamination solution (5-10% sodium carbonate) and allowing them to stand unsealed for at least 48 

hours. Used decontamination solution and rinse water should be disposed of as hazardous wastes in strict 

accordance with all applicable federal, state, and local laws and regulations.) 

CAUTION: Remember, TDI is listed as a hazardous waste under Section 261.33(f) of EPA’s RCRA regulations 

and requires special handling for disposal. Additionally, shipments of RCRA empty drums are subject to DOT 

hazardous material regulations unless the container is completely cleaned and purged of the material so that 

no hazard exists. See 49 CFR § 173.29. 

Compliance with RCRA’s one-inch residue rule is not sufficient to meet DOT’s standard of “cleaned and 

purged.” If the container must be shipped with residue, then under DOT regulations, all labeling, marking, 

packaging, and shipping paper requirements and placarding must be followed. 

WARNING: Under no circumstances should empty drums be burned or cut open with a gas or electric torch, as toxic 

decomposition products may be liberated. 

(6) According to RCRA, 40 CFR § 261.7, an empty container is on that is “drip dry” - i.e., one that has been emptied of all materials which 

can be removed using the practices commonly employed to remove materials from that type of container; e.g., pouring, pumping, or 

aspirating. (Note that the “one inch” residue rule for determining whether a drum is empty applies only to nonflowable products, such 

as very viscous resins.) Drums which have contained an acutely hazardous waste must be triple rinsed. 


7



2.8 Recommended Formulations for Decontaminant Solutions 

Formulation 1 Weight or Volume % 

Water 90-95 

Concentrated ammonia 1 solution 3-8 

Liquid detergent 0.2-2 


Water 90-95 

Sodium carbonate 5-10 

Liquid detergent 0.2-2 

For routine operations, for example, decontamination of protective equipment, tools and parts of machines, the following formulation 

is more effective. The solution is flammable and should be handled accordingly. 


An alcohol (ethanol, isopropanol or butanol) 50 

Water 45 

Concentrated ammonia1 solution 5 


Water 75 

Non-ionic surfactant 20 

n-propanol 5 

* Care should be taken when handling ammonia because it is a hazardous material. 




Chapter 3: Safety Auditing of Tank Truck Carriers and Bulk Tank Operators 

3.1 Carrier’s Capability: Assessment and Control 

All TDI manufacturers should use the services of professional tank truck carriers for distributing their 

products. Manufacturers should be sure that the carriers employed are competent and operate to 

appropriate safety standards. Manufacturers should be aware that carriers sometimes will subcontract with 

another carrier. To ensure that a shipper is aware of any such arrangements, a shipper may include a 

provision in its motor carrier contract requiring the shipper’s consent to any subcontract, and establishing 

appropriate safety criteria. 

3.2 Carrier Safety Audits 

All shippers involved in transporting TDI should undertake safety audits of their tank truck carriers and bulk 

tank operations periodically. This will enable each shipper to verify that the motor carriers comply with 

applicable environmental and safety regulations and adhere to general industry safety standards. To protect 

against liability in the event of an accident, shippers should consider seeking an indemnity provision in the 

contract. This would indicate that they are to be indemnified by the carrier in the event the shipper is sued 

because of the carrier’s failure to comply with applicable regulations or general industry safety standards or 

guidelines. 

3.3 Carrier Safety Audit Procedure 

A carrier safety audit protocol and procedure has been produced by the American Chemistry Council to be 

utilized as a guideline in conducting safety evaluations of the carrier. This guideline may provide useful 

information that may be the basis of a carrier audit for those engaged in the transport of TDI. 

3.4 Meeting Safety and Regulatory Standards 

Auditing does not replace or diminish the basic responsibility of the carrier to ensure that his distribution 

practices meet the appropriate safety, health, and other regulatory standards and potentially hazardous 

substances are properly maintained as required by the various federal, state and local regulatory statutes and 

regulations. 

3.5 Scope 

While this section deals with bulk transportation, similar care is required in selecting competent carriers to 

transport intermediate bulk and non-bulk packaging. TDI suppliers may wish to consult the American 

Chemistry Council Carrier Safety Assessment and Audit Protocol procedures for this purpose. 


9






Chapter 4: Design and Construction of Transportation Equipment 

4.1 Rail Tank Cars (RTCs) 

Rail tank cars used for the transportation of TDI must meet the US Department of Transportation’s design 

and construction requirements for the transportation of hazardous materials. These requirements are found in 

49 CFR Part 179. The various sub-parts of Part 179 describe the requirements for construction material, 

welding, wall thickness, gaskets, valves, valve protection, and venting devices. 

Specific additional recommendations are as follows: 

• All fittings on rail tank cars should be clearly labeled. 

• Tanks should be thermally insulated to minimize temperature fluctuations and to provide extra protection 

in the event of fire or other accident. 

• Heating coils should be located on the exterior of the tank. 

• Tanks may be constructed of mild steel. The tanks may be internally lined. 

• Tanks should be fitted with 2-inch connections for vapor return lines. 

• Although the DOT’s Hazardous Materials Regulations permit bottom outlets, diisocyanate producers 

recommend only top unloading outlets. 

• Pressure relief valves should be present and should be set to 75% of the pressure rating of the tank car. 

• If present, vacuum relief valves should be utilized to prevent negative internal pressure and should be set 

at 1 psig. 

• External fittings should have rollover or crash protection so that the tank car will not leak when involved 

in an accident. 

• Thermowells for temperature measuring devices should be present and have the appropriate relief 

devices to prevent spraying of product in the event of a malfunction of the thermowell. 

• Fittings should be available for pressurizing the car with dry nitrogen or dry air to assist in unloading or 

to apply a blanket to prevent moisture ingress. 

• TDI should not come in contact with aluminum, brass, copper, zinc, or their alloys due to corrosion (loss 

of integrity). 

4.2 Cargo Tanks (Tank Trucks) and Inter-modal Bulk Tank Containers (ISOTainers) 

Cargo Tanks and ISOTainers used for the transport of TDI must meet the design and construction requirements 

of the US DOT. In addition, Cargo Tanks and ISOTainers should be designed and constructed in accordance 

with the following recommendations: 

• When TDI is shipped in a DOT specification container permitted by 49 CFR Part 173, it must conform to 

the applicable design specifications under Part 178. 

• Each tank must be fitted with a pressure relief device as prescribed in the appropriate section of the 

DOT’s regulations. 


11



• Each tank should be fitted with vacuum relief devices as prescribed in the appropriate section of DOT’s 

regulations. 

• Loading outlets must be equipped with valves and unloading outlets should terminate in a 2-inch 

diameter male quick connect fitting with proper closure cap. 

• The vapor return valves should be 2-inch diameter and terminate in a quick connect fitting with proper 

closure cap or plug. 

• The air-line valve should be 3/4-inch and terminate in a Chicago coupling with proper closure cap or plug. 

• It is very important to prevent atmospheric moisture from entering the tank during off-loading. Dry 

nitrogen is preferred for pressure off-loading. When dry nitrogen is not available, a tank may be 

pressurized using air from the tractor compressor or other source, provided it moves through a desiccant 

dryer at the proper CFM prior to entering the tank. The desiccant drier must be capable of drying the air 

to a dew point of -40°F. All customer-supplied air or nitrogen should be routed through the carrier’s 

desiccant dryer. 

• Heating systems, when used, should be external and equipped with a temperature-control device 

(manual or electronic). 

• Off-loading hoses should be 2-inch diameter, color-coded red, and stamped “For Diisocyanate Use 

Only.” Materials of construction should be suitable for diisocyanates. The hoses should be clean, dry 

and capped when not in use. Pressure testing is recommended prior to their first use and at least 

quarterly thereafter. 

4.3 Intermediate Bulk Containers (IBCs) 

Intermediate Bulk Containers may be used for the transportation of TDI by road, rail, sea, or inland waterway. If 

used, they must meet the DOT and IMDG design and construction requirements for the particular transport modes. 

DOT 51 is an approved portable tank for TDI. DOT 56 and 57 portable tanks manufactured after September 

30, 1996 can not be used. DOT 56 and 57 portable tanks manufactured prior to October 1, 1996 may 

continue in hazardous materials service for the commodities currently authorized as long as they meet the 

retest requirements in paragraph (e) of Section 173.32. These requirements are as follows: 

a. DOT 52, 53, 56 and 57 portable tanks are required to be retested every 2.5 years. 

b. DOT 51 portable tanks must be retested every 5 years. 

c. Dual marked portable tanks certified to both pre-October 1, 1996 DOT 56 or 57 specifications and the 

metal IBC standards must conform to the pre-October 1, 1996 retest requirements and the metal retest 

and inspection requirements adopted in the IBC final rule. 

In addition to the above requirements, IBCs should comply with the following suggestions: 

4.3.1 Filling Standards 

Before being filled and offered for transportation, each IBC and its service equipment must be visually 

inspected to ensure that it is free from any damage that would render it unsafe for transport. 49 CFR 

§ 173.35(b). 




When filling an IBC with liquids, sufficient ullage must be left to ensure that, at the mean bulk temperature 

of 50° C (122° F), the IBC is not filled to more than 98% of its water capacity. 49 CFR § 173.35(d). 

4.3.2 Construction and Performance Standards 

Section 178.705 specifies the construction requirements for authorized metal IBCs. Additionally, 

these containers must satisfy the following performance tests, which are detailed under sections 

178.810-815 and 178.819: 

• Vibration; 

• Bottom lift and/or top lift (depending on how the container is intended to be handled); 

• Stacking; 

• Leakproofness (liquids only); 

• Hydrostatic (liquids only); and, 

• Drop Tests. 

Each new container must be visually inspected and be leakproofness tested (if containing liquids) 

every 2.5 years from the date of manufacture. 49 CFR § 180.352. 

4.3.3 Recordkeeping 

The IBC owner or lessee must keep records of periodic retests and initial and periodic inspections. 

Records must include: 

• Design types and packaging specifications, 

• Test and inspection dates, 

• Names of tests and the names and addresses of test and inspection facilities, 

• Names of persons conducting tests or inspections, and; 

• Test or inspection specifics and results. 

Records 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 

TDI is classified as a hazardous material by the DOT. If TDI is shipped in drums, the drums must 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). Drums must be constructed in conformance with the standards 

applicable for the particular material of construction. See 49 CFR §§ 178.504-509. 

Additionally, drums must meet the performance tests prescribed in the regulations. See 49 CFR §§ 178.600- 

178.608. These regulations also include a requirement 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. 


13



Drum material, including any fitting, must be compatible with the product. 49 CFR § 173.24(e) Drums must 

be inspected for integrity, tightness, dryness, cleanliness and lack of rust or foreign particles before filling. 

See 49 CFR § 173.22(a)(2). Additionally, all disocyanate producers agree that open head type drums should not 

be used for TDI due to the potential for leakage and/or contamination. 

4.4.1 Drum Specifications 

Drums used for the shipment of TDI must satisfy the specifications provided for in 49 CFR § 178.504- 

.506 & .508-.509. Additionally the drums must satisfy the performance tests indicated in 49 CFR 

§ 178.600-.608. TDI manufacturers do not recommend use of open-top drums for TDI or other 

materials containing TDI. 

4.4.2 Drum Handling 

Personal Protective Equipment 

Persons handling drums should have the proper personal protective equipment. 

Transporting Drums 

Drums should be transported by lifting, to avoid damage caused by sliding or rolling. Only 

equipment designed for handling drums should be used, such as fork-lift trucks equipped with 

“parrot beaks” or drum clamps. (CAUTION: Drum clamps should not be used on the Euro “W” style 

drum now used by many diisocyanate suppliers) Once loaded/unloaded, the responsible party should 

examine the drums to check for damage or leaks. If any drums are found to be leaking, the 

procedures for spill response should be followed. 

Emptying Drums 

Drums may be gravity discharged or emptied using a standard immersion pump. Air displaced from 

the receiving tank should be properly treated to ensure that TDI vapors are not released into the 

atmosphere. The drum should be vented to prevent collapse when pumping out material, or to 

facilitate flow when gravity feeding material. A small canister of silica gel (desiccant) should be 

installed in the drum’s vent opening to prevent atmospheric moisture from entering the drum as 

liquid is transferred out. The opening of drums should be minimized to reduce moisture 

contamination. Do not use pressure to unload drums. 

Caution: Contamination Problems 

Water contamination of drums should be avoided. TDI reacts with water to generate CO2 gas, which 

can cause a potentially dangerous pressure build-up in the container. This reaction is accelerated at 

high temperatures (120°F). Drums showing evidence of pressure build-up should be vented 

immediately with caution; otherwise, there is a potential for a violent drum rupture. 




Chapter 5: HazMat Training 

5.1 Training Requirements 

Under 49 CFR §§ 172.700-704, all employees handling hazardous materials, including drivers, must be 

trained in each of the following areas: 

• General Awareness 

• Function Specific 

• Safety 

DOT requires that all persons involved in the preparation of hazardous materials for transport be trained in 

accordance with the hazardous materials regulations within 90 days of employment or a change in job 

function. Prior to training, an employee must be directly supervised by a trained individual. Refresher training 

every 3 years is required for all employees handling hazardous materials. Further, employees should be 

advised of changes in the law that occur during that time that affect their job performance. 

Records must be maintained on all personnel who receive DOT training, both supervisory and non-supervisory 

personnel. Each employee must have his or her own training log (the formal record) inclusive of the preceding three 

years. The employer must retain the training log for as long as that employee is employed and for 90 days thereafter. 

5.2 Specific Requirements for TDI 

Because TDI is a DOT-regulated hazardous material, drivers must be specifically trained to understand the 

particular nature of the dangers that may arise during the transport of this material and how to handle an 

emergency. A guideline for drivers is contained in Appendix 2. Under DOT’s regulations, an employer whose 

employees are involved in handling hazardous materials is responsible for ensuring that they are properly 

trained. See 49 CFR §§ 172.700-704. This means that both shippers and carriers are independently 

responsible for ensuring compliance with the training requirements. 

5.3 Driver Criteria for Transporting TDI 

Before a driver is allowed to transport a hazardous material like TDI, he must have: 

• Received training to the standard required by Federal, State and local regulation and obtained a 

Commercial Drivers License (CDL) and a Hazardous Materials endorsement on his/her license as 

required by 49 CFR §§ 383.71-383.155. 

• Received TDI specific training as part of his required function-specific training. 

5.4 Certified Drivers 

Before a shipper enlists a carrier he should: 

• Ensure that the carrier can document that all drivers transporting TDI have been trained in accordance 

with DOT’s regulations. 

• Include training as an item to be addressed in the carrier audit program mentioned in Sections 3.2 to 3.5. 


15






Chapter 6: Personal Protective Equipment for Loading or Unloading TDI 

When transferring TDI, personal protective equipment should be worn by employees and/or drivers engaged 

in these activities if the possibility of exposure exists. This may, depending upon conditions (i.e. TDI vapor 

exposure), consist of: 

• Self contained breathing apparatus or airline system with full face piece, operated in a pressure demand 

or positive mode, or an air-purifying respirator with an appropriate cartridge change-out schedule; 

• Chemical gloves, impervious to TDI (butyl rubber, nitrile rubber, PVA);* 

• Full body protection, impervious to TDI;* 

• Fitted boots made of material(s) impervious to TDI,* and; 

• Head protection, such as a close fitting hood, made of a material impervious to TDI.* 

Taking samples for quality control analysis during off-loading is not recommended because of the potential 

for exposure. 

The use of suitable respiratory equipment is required whenever there is a potential for exposure to airborne 

TDI levels in excess of permissible exposure limits (PEL 0.02ppm-ceiling, TLV 0.005ppm - 8hour TWA). 

For additional information on Personal Protective Equipment (PPE) refer to the manufacturer’s Material Safety 

Data Sheet. 

• See API Technical Bulletin - TDI User Guidelines for Chemical Protective Clothing Selection (AX-179) for protective glove/clothing 

permeation data. 


17






Chapter 7: Loading Operations 

7.1 Compliance With Transport Regulations 

The shipper and the carrier should work together to ensure compliance with transport regulations. 

7.2 Criteria for Loading Facilities and Transport Equipment 

The act of filling any container with a hazardous material is potentially dangerous. It is therefore important 

that loading facilities and transport equipment be correctly designed and constructed, as well as properly 

used and well maintained. 

7.3 Design and Construction of Transport Equipment 

The design and construction of transport equipment is described in Section 4 of these Guidelines. Equipment 

used in the transportation of TDI is subject to periodic inspection and testing requirements by the carrier as 

specified in DOT’s regulations. 

7.4 Availability of Written Operating Instructions 

Written operating instructions should be made available covering the loading of TDI into bulk tank trucks, 

inter-modal tanks and containers, rail tank cars, multi-unit tank car tanks, intermediate bulk containers, and 

non-bulk packaging. Additionally, persons involved in shipping TDI must be fully trained in accordance with 

DOT’s hazardous materials regulations. Information regarding the specific hazards of TDI must be 

communicated to all individuals involved in the loading/unloading or transportation of TDI. 49 CFR § 172.600. 

Additionally, such persons must be trained in the proper procedures for the operation of the filling equipment 

in both normal operations and in any emergency situations (see Section 11.3 for further relevant details). 

Drivers also must be familiar with safety procedures, including the use of safety equipment at the loading 

point. See 49 CFR § 172.704(a)(3). 

7.5 Availability of Personal Protective Equipment 

Appropriate personal protective equipment must be available for loading operations and persons must be 

trained in the correct use of this equipment. See 29 CFR § 1910.132. Whenever the driver leaves his vehicle, 

he should take with him the appropriate personal protective equipment to ensure its availability in the event 

of an emergency. See Chapter 6. 

7.6 Inspection of the Bulk Transport Equipment 

These Guidelines do not attempt to set detailed operating instructions for filling TDI containers since these, 

of necessity, will depend upon local operating conditions. However, the operating instructions should specify 

that loading personnel inspect the bulk transport equipment before and after loading and that loading 

personnel attend the transfer process. This inspection does not replace or diminish the responsibility of the 

operator of bulk transport equipment to ensure that it is properly tested, maintained, fit for its intended 


19



purpose and ready for loading. It is meant to ensure that the loading and unloading of TDI is conducted as 

safely as possible. The inspection list detailed in Appendix 6 is a guideline that loaders may use to check the 

condition of the bulk transport equipment before and after all filling operations. Individual companies should 

develop their own detailed operating instructions that include inspection procedures. 

7.6.1 Routine Inspection of Tank Trucks and IMO Containers at Loading 

Terminals 

Administrative procedures 

The shipper should verify that: 

1. The driver has a valid CDL certificate for the transport of hazardous materials. 

2. The driver has received TDI-specific training. 

3. The trailer/container capacity is adequate for the quantity to be loaded and, when loaded, the 

total gross weight is within regulatory limits. 

Before loading 

The carrier should have a comprehensive pre-loading procedure that includes, as a minimum, 

verification that: 

1. The unit is in compliance with all DOT required inspections, including: 

• DOT standard equipment; and, 

• Air-dryer, insulation, heating device, temperature gauge, safety relief valves (pressure and 

vacuum), vapor return connection, air valve and sampling valve, if required. 

2. All the valves, domes and manways are closed upon arrival. 

3. The correct caps or blind flanges have been fitted with all the necessary bolts and gaskets. 

4. The vehicle has all the necessary equipment in good working order. 

5. The person in charge of the operation has been notified of the quantity to be loaded. 

During loading 

1. Continuous monitoring of the loading operation is required. 

2. Ensure that the required filling levels are not exceeded. 

After loading 

The shipper and the driver should verify that: 

1. The maximum permitted gross weight for the vehicle and container has not been exceeded. 

2. All valves have been closed and blind flanges, caps, plugs, and domes have been properly secured. 

3. The exterior of the tank is clean and free from product residue. 

4. Proper toxic placards and U.N. identification numbers for TDI (UN-2078) are attached. 

5. The tank truck is equipped with all hoses and fittings required for unloading. 




7.6.2 Routine Inspection of Rail Tank Cars (RTCs) 

Administrative Procedures 

The shipper should verify that: 

1. The Rail Tank Car is DOT approved and authorized for TDI transport. 

2. The safety valve and tank test dates are current. 

3. The carrier has been provided with the appropriate shipping documentation and emergency 

response information. 

Before loading 

The shipper should have a comprehensive pre-loading procedure that includes, as a minimum, 

verification of the following: 

1. The Rail Tank Car is in good physical condition and is safe to transport TDI. 

2. All the valves and the manway are properly secured. 

3. The Rail Tank Car capacity is adequate for the quantity to be loaded. 

4. All valves function correctly and have passed a pressure test. 

During loading 

The shipper and/or carrier shall do the following: 

1. Monitor the loading operation continuously. (49 CFR § 174.67). 

2. Ensure that the required filling level is not exceeded. 

After loading 

The shipper should have a comprehensive post-loading audit procedure that includes, as a minimum, 

verification that: 

1. The car’s gross weight has not been exceeded. 

2. All valves, blind flanges, the manway lid and the valve cover hatch lid have been properly secured. 

3. All seals or locks are in place. 

4. The outside of the tank is clean and free of product residue. 

5. All appropriate hazardous material placards and the identification numbers for TDI (UN-2078) 

are affixed. 

7.6.3 Maintenance of Transport Equipment 

During operations, unscheduled maintenance of the transport equipment may be necessary. The 

chemical reaction of TDI with water in the atmosphere leads to the formation of urea, which could plug 

the valves and block the pressure relief valves and piping. Customers should be instructed to 

immediately report any difficulties to the shipper and to their maintenance department. One means of 

communicating is to attach an information tag that identifies problems to the returning transport 

equipment. 


21



7.7 Inspection List: Modifications 

The inspection list assumes that TDI is to be loaded and transported domestically. In circumstances where 

TDI is to be shipped internationally — in accordance with regulations that may differ from the requirements of 

the DOT — the inspection list should be modified as appropriate. 




Chapter 8: Transport of TDI by Rail 

8.1 Responsibilities of Rail Tank Carrier 

Rail carriers are responsible for the safe transport by rail from dispatch siding to final reception siding. See 

49 CFR Part 174. The selection of the routes, intermediate stopping locations, and cessation of traffic 

because of severe weather conditions are matters to be decided by the railway authorities, and should be 

reported to the shipper. 

8.2 Emergency Intervention 

The relevant federal, state or local authorities may intervene in the event of a transport emergency involving 

rail tank cars containing TDI. Shippers must provide rail carriers with the appropriate emergency response 

information, along with a 24-hour contact number. See 49 CFR §§ 172.600-604. 

8.3 Inter-Modal Movements 

Where inter-modal (i.e., road/rail/road) movements are arranged that are not driver/tractor accompanied 

during the rail stage, particular attention must be given to ensuring that the motor carrier leg of the journey 

has the appropriate shipping and emergency response information. 


23






Chapter 9: Transport of TDI by Road 

The carrier is responsible for the safe transport of TDI by road from the loading point to the discharge (unloading) 

point. The following summarizes basic regulatory provisions and highlights industry recommendations: 

9.1 Routing 

The route to be followed must be selected carefully by the carrier and should be given, upon request, to the 

shipper. Compliance with bridge, tunnel or local routing regulations and restrictions is the responsibility of the 

carrier. DOT requires carriers of hazardous chemicals to utilize routes that: 

• follow major highways and/or designated truck routes, and; 

• avoid areas of high population density. 

Exceptions to the above restrictions are permissible only where “there is no practicable alternative.” See 49 

CFR § 397.9. 

9.2 Safe Parking 

Motor vehicles containing hazardous materials (with the exception of explosives which are treated separately) 

must not be parked on or within five feet of the traveled portion of a public street except for brief periods when 

the “necessities of operation require the vehicle to be parked and make it impracticable to park the vehicle in any 

other place.” See 49 CFR § 397.7. A secure depot or secure factory premises should be used whenever possible. 

Preferably, parking should be in an isolated location that is illuminated at night. It is strongly recommended 

that receivers allow secure parking to vehicles that have arrived outside specific access times. 

9.3 Severe Weather Conditions 

When severe weather conditions exist (i.e., icy roads, snow or poor visibility) that may affect the ability of the 

driver to proceed safely with the shipment, the vehicle should stop at the first suitable parking place. The 

driver should not continue with the delivery until the weather conditions improve. See 49 CFR § 392.14. 

9.4 Delays or Accidents 

All delays during transport, whether caused by severe weather conditions, breakdown or any other reason, should 

be reported to the shipper as soon as possible. In the event of an accident involving the immobilization of the 

vehicle, product spillage, or threatened loss of containment, the driver must contact the 24-hour emergency 

contact number, and follow any procedures specified in the emergency response information provided by the 

shipper. In addition, details of the accident must be reported to DOT in accordance with DOT’s reporting 

requirements. See 49 CFR § 171.16. 

Also, the U.S. Environmental Protection Agency considers TDI an extremely hazardous substance. Thus, if 

more than 100 pounds of TDI is spilled or otherwise released into the environment, the shipper is responsible 

for immediately reporting the release to the National Response Center and the local 911 operator. See 40 

CFR §§ 302.6 and 355.40. 


25



9.5 Inspections During Transport 

Under the DOT’s regulations, a driver must examine the vehicle’s cargo and its load-securing devices within 

the first 25 miles after beginning a trip and make any adjustments to the cargo or load-securing devices 

(other than steel strapping) as may be necessary to maintain the security of the commercial motor vehicle’s 

load. 49 CFR § 392.9(b)(2). The truck driver then must periodically examine the vehicle’s cargo during the 

course of transportation as follows: 

• when the driver makes a change of duty, 

• after the vehicle has been driven for 3 hours, or; 

• after the vehicle has been driven 150 miles, whichever occurs first. 49 CFR § 392.9(b)(3). 

For the bulk transport of TDI, the temperature of the tank contents should be checked regularly (detailed above) 

and recorded manually or electronically. If the temperature of the tank contents should rise more than 10°F 

above that specified by the shipper, the driver should immediately telephone the shipper to seek instruction. 




Chapter 10: Transport of TDI by Water Vessel 

10.1 Approved Containers 

Transportation of TDI by ocean vessel must be in accordance with the International Maritime Dangerous 

Goods Code (IMDG). To the extent permitted by the IMDG Code, TDI may can be transported as follows: 

• Inter-modal tank containers, by roll on/roll off chassis; use of a 40 foot drop-nose type is recommended. 

• Inter-modal tank containers that are lifted on/off of container vessels. 

• In bulk ocean tankers or inland waterway vessels (not covered by these guidelines. See Chapter 1.5). 

• In metal intermediate bulk containers that should be transported in freight containers. 

• In non-bulk packaging such as drums that should be transported in freight containers. 

10.2 Parties Involved 

Because of the nature of the activity, a number of different parties may be involved in transporting TDI from 

shipper to customer. These may include shipping companies, freight forwarders, port or harbor authorities, 

and carriers. 

10.3 Safety Audits 

The shipper should consider carrying out a safety audit of the following distribution operations: 

• Forwarding operators; 

• Loading and unloading facilities at container terminals; and, 

• Emergency handling within hazardous cargo yards and container terminals. 


27






Chapter 11: Unloading Operations for Tank Trucks and Rail Tank Cars 

11.1 Criteria for Discharge Facilities 

The operation of discharging TDI from any bulk container may present risk of certain physical and health 

hazards. Consequently, it is important that discharge facilities be correctly designed and constructed, and 

properly used and maintained. 

11.2 Design, Location and Checks 

Discharging facilities should be designed and located for the handling requirements associated with TDI. A 

preventive maintenance program covering all equipment should be developed to ensure proper operation 

(See Appendix 2 & 3.) 

11.3 Criteria for Discharge Hoses 

All discharge hoses and vapor return hoses should be specifically selected for TDI service, be 

marked/labeled “For Diisocyanates Service Only”, and be equipped with a safe means of sealing the hose 

when not in use. Two-inch diameter hoses are the recommended industry standard for unloading TDI and for 

vapor exchange. 

11.4 Operating Procedures 

Written operating procedures should be prepared covering all aspects of the discharge of TDI. In the case of 

tank truck unloading, division of responsibilities between the driver and receiver should be clearly defined. 

For attendance requirements, see 49 CFR § 177.834 for tank truck unloading and 49 CFR § 174.67 for rail 

tank car unloading. See Appendix 2 for specific recommendations on the division of responsibilities between 

the tank truck driver and the receiver. See Appendix 3 for specific recommendations for unloading from a rail 

car. 

11.5 Protective Equipment for Operators 

All necessary personal protective equipment should be available for discharging operations (See Chapter 6 

for further details). It is the shippers’ responsibility to provide to his employees the proper personal protective 

equipment and to ensure that they are trained in its use. The carrier and the customer have the same responsibilities 

for their employees. 

11.6 Inspection of the Bulk Reception Facilities 

The customer is generally responsible for controlling the conditions of receipt. Customers should work with 

their suppliers to ensure that good safety standards have been developed for handling and storage. See 

Appendix 4 for a checklist of general industry recommendations that provides companies with guidelines for 

ensuring the safe handling and storage of TDI. 


29






Chapter 12: Required Shipping Information for TDI 

12.1 TDI’s Hazardous Materials Classification 

When in transport, TDI is classified as a Division 6.1, Packing Group II toxic substance. This classification 

triggers a number of regulatory requirements when a company offers a material for either domestic or 

international shipment. The principles of DOT hazardous materials regulations are as follows: 

• A company offering TDI for transport must complete a shipping paper indicating the required shipping 

information for TDI. 49 CFR §§ 172.200-.203. This information varies slightly depending on whether the 

material is moving in domestic (U.S.) or international commerce. See subsection 12.2 below. 

• The shipping paper must include an emergency contact telephone number that is manned twenty-four 

hours a day. 49 CFR § 172.604. (Within the U.S., all major producers are members of a mutual aid 

program known as CHEMTREC, which is available through the American Chemistry Council). If shipping 

TDI as a waste, the Hazardous Waste Manifest must be completed as required. 49 CFR § 172.205. 

• The shipping paper must include the required shipper’s certification that the material is shipped in 

compliance with the regulations. See 49 CFR § 172.204. 

• Emergency response information must be included with the shipping paper and provided to the carrier. 

See 49 CFR §§ 172.600-602. 

• As required by DOT’s regulations, all TDI must be appropriately: 

– packaged (49 CFR § 173.202 (non bulk) or 49 CFR § 173.243 (bulk) and 49 CFR § Part 178); 

– marked (49 CFR §§ 172.300-338); and 

– labeled and placarded (49 CFR §§ 172.300-.338, 172.400-.448 and 172.500-.560). 

12.2 Summary of TDI Hazard Information* 

DOT 

Proper Shipping Name Toluene Diisocyanate 

Hazard Class 6.1 

U.N. Number U.N. 2078 

Packing Group II 

Reportable Quantity** 100 lbs. 

Label/placard toxic 

IMDG 







31



ICAO 






Maximum Quantities per Package Refer to regulations or air carrier for guidance 

* Information in italics should be entered on the shipping paper in the order shown. Other information is provided for easy reference. 

** Shipments of TDI exceeding 100 lbs. in one container must have the letters “RQ” entered on the shipping paper and marked on the packaging. 

12.3 Preparedness and Emergency Response 

Companies should be prepared to provide on-scene assistance and expert advice in remedial action 

procedures. In cases where local, state or federal authorities are in control of the incident, the role of the 

company responders should be to: 

• Operate fully within the company’s Site Specific Emergency Response and Safety and Health Plan. 

• Assist in the establishment of an Incident Management System and provide technical advice based upon 

product knowledge to the On-Scene Command (OSC). 

• When conditions warrant, and as requested by the OSC, organize the provision of spare 

vehicles/pumps/hoses/other equipment for the cargo transfer, decontamination, and be prepared, on 

behalf of the OSC, to employ their technical expertise in conducting or supervising remedial action. 

12.4 Principles of Emergency Response Scheme 

The principles of the scheme should be: 

• If the producer cannot respond promptly to an incident that requires on-scene assistance, the producer 

may request a nearby chemical company to respond. If another company cannot respond, the shipper 

may seek a for-hire response company. 

• Only chemical companies and for-hire responders that are qualified to handle the hazards of TDI 

involved in the incident will be requested to respond. 

• Response by a chemical company to another shipper’s incident is discretionary. 

• The producer will, upon request, reimburse the responding company for reasonable expenses, or pay a 

for-hire company in accordance with the current schedule of charges in effect under their contract. 

• All companies participating in these arrangements will make available such services and assistance as 

would be provided for their own TDI. 

12.5 Technical Communications 

Regular technical communications should be established between participating companies in order to 

recommend methods of resolving transportation/distribution incidents. 




Appendix 1: Sample Certificate of Receipt 

1 Part A: (To be completed by the receiver of bulk tank truck loads BEFORE discharge is started) 

I hereby certify that the following has occurred: 

• The TDI can be safely received by the storage facility. 

• The TDI to be received is the same as described on the bill of lading. 

• The unloading arm or hose is connected to the correct lines and/or piping and unloading may begin. 

• The storage tank(s) receiving the TDI have adequate space for the entire quantity being delivered. 

Signature ........................................................ Date ................................... 

1 Part B: (To be completed by the receiver of bulk loads AFTER discharge is started) 

I certify that the item shown on the bill of lading has been received. 

Signature ........................................................ Date ................................... 

* This document is provided for guidance purposes only, as one way of verifying that TDI has been received and properly unloaded. 

Individual company practices may vary. 

(1) Tank truck carrier Bill of Lading will require both of these signatures. 


Appendix 1-1



Appendix 1-2 Copyright 2002, American Plastics Council



Appendix 2: Guidelines for the Unloading of Tank Trucks 

This appendix contains guidance for off-loading tank trucks with a suggested division of responsibilities 

between the driver and receiver. Because of variations in the configuration of a customer’s facilities, the 

specific activities involved, or the sequence in which they are conducted, may differ from what is described 

in the appendix. 

The purpose of this appendix is to demonstrate the complexity of the operation and the need for a clear 

understanding of the division of responsibility between those involved. 

The driver has a legal duty to protect the integrity of a hazardous material. The receiver has a duty to ensure 

that product is safely discharged in the proper tank. Both should cooperate fully in the discharge process to 

ensure that it is conducted safely. 

U.S. Department of Transportation regulation 49 CFR § 177.834 requires that throughout the entire period of 

unloading and while the tank truck has unloading equipment attached, a qualified person must attend the cargo 

tank unloading process to ensure safety. The current DOT attendance requirements demand “physical on-site 

attendance by a person who is alert, is within 25 feet and has an unobstructed view of the unloading 

operation.” 


Appendix 2-1



Suggested Checklist for Tank Truck Unloading 

Receiver Activities 

1 ____ Verify your facility expects to receive a 

____ delivery. 

3 ____ Direct the tanker to the unloading point. 

4 Verify: 

____ the amount to be unloaded can be 

accepted in the storage tank. 

5 Verify: 

____ the product name on the bill of lading is 

what you are expecting to receive. 

____ the same tank/truck number appears on 

the bill of lading, packing list and COA 

____ the proper unloading connection for the 

product. 

8 ____ Secure area with signs or barricades. 

9 Tell the driver where to find: 

____ the shower. 

____ the eyewash. 

____ the fire extinguisher. 

____ the telephone or intercom and brief the 

driver on site emergency procedures. 

Driver Activities 

1 ____ Drive to the receiving area. 

2 Give the receiver: 

____ bill of lading. 

____ packing list. 

____ scale ticket. 

____ certificate of analysis. 

6 ____ Position vehicle as directed by the receiver. 

7 Prepare vehicle for unloading: 

____ apply the brake. 

____ chock wheels with 2 chocks. 

* Show the unloader the location/operation of 

the emergency shut off for the unloading 

valve. 






10 Put on personal protective equipment: 

____ appropriate respiratory protection. 

____ chemical gloves, impervious to TDI.* 

____ long-sleeve coveralls or full body suit, 

impervious to TDI.* 

____ fitted boots made of material(s) 


____ head protection, such as a close fitting 

hood, made of material impervious to TDI.* 

11 ____ Make sure that all valves in the receiving 

system are fully closed. 

13A ____ Take sample to laboratory if required. 

13B ____ Inspect the hoses and gaskets prior to 

connection. 

14A ____ Securely connect the unloading hose to 

the storage facility. 

15A ____ Record start level in storage tank. 

15B ____ Sign the drivers Bill of Lading to indicate 

a good hookup has been made. 

16 ____ If the product conforms to specification, 

start the unloading procedure. 

17 ____ Check driver’s action. 



10 Put on personal protective equipment: 

____ appropriate respiratory protection. 

____ chemical gloves, impervious to TDI.* 

____ long-sleeve coveralls or full body suit, 


____ fitted boots made of material(s) 


____ head protection, such as a close fitting 

hood, made of material impervious to TDI.* 

11 ____ Make sure that all vehicle valves are 

fully closed. 

12 ____ Take sample if required (not recommended) 

13A ____ Inspect hoses, fittings and gaskets prior 

to connection. 

14B ____ Assist receiver and securely connect 

hose to tank truck. 

15B ____ Ensure the customer has signed the 

carrier Bill of Lading indicating a good 

hookup has been made. 

For Pump Discharge Only: 

18A ____ Install the vapor return line connection to 

the vehicle. 

* See API protective glove/clothing permeation data—TDI User Guidelines for Chemical Protective Clothing Selection (AX-179). 

Appendix 2-3





19A ____ Open valve in the receivers unloading and 

vapor piping. 

20 For Pressure Discharge Only: (in sequence) 

A ____ Open vent line on storage tank. (Vent line 

must be connected to an effective 

scrubber system such as an activated 

carbon canister of sufficient capacity, 

installed and maintained in accordance 

with manufacturer’s recommendations.) 

B ____ Keep vent line open throughout product 

transfer. 

C ____ Connect nitrogen or dry air supply to the 

trailer and open valves to pressurize the 

trailer. 

D ____ Open the nitrogen supply valve, or if dry 

air is used, pass the air through the 

carriers desiccant dryer. 

E ____ When proper pressure has built up in the 

tank truck, open the valve on receiver’s line. 

21A ____ Observe and control the transfer including 

product level in the receiving tank. Any 

anomaly linked to product discharge 

systematically implies: 

____ stopping the discharge. 

____ immediately informing the management 

and seeking instructions. 

____ recording the incident. 


18B ____ Ensure tank truck vapor return valve 

is open. 

20E ____ Open tank truck outlet (external) valve 

and check the system to ensure no leaks. 






22 When the transfer operation is complete: 

For Pump Discharge Only: (in sequence) 

A ____ Manipulate hose to provide gravity flow 

to pump enhancing hose drainage. 

B ____ Close valve on receiver’s line. 

C ____ Stop pump. 

D ____ Close valve on vapor return line. 

For Pressure Discharge Only: (in sequence) 

23A ____ Close nitrogen supply valve or shut off air 

compressor and close dry air valve. 

C ____ Close valve on receiver’s line. 

D ____ Close vent line on storage tank. 

24 ____ Bleed pressure off, then disconnect the 

unloading hose; cap and stow away 

safely. Driver assist. We recommend 

carrier supplied hoses. If using carrier 

hoses, this is a driver activity. 



A ____ Driver assists. 

22E ____ Close tank truck internal valve. 

F ____ Close tank truck external valve. 

G ____ Close tank truck vapor exchange valve. 

23B ____ Ensure the unloading hose has been 

blown empty. 

23E ____ Close internal valve. 

F ____ Close tank truck external valve. 

25 ____ Secure trailer connections. 

Appendix 2-5





26 ____ Remove personal protective equipment, 

carefully cleaning any items contaminated 

during the discharge process. 

27A ____ Record stop level in storage tank. 

B ____ Certify receipt, sign driver’s bill of lading 

and paperwork, and authorize driver to 

leave the transfer point. 

28 ____ Leave the transfer point. 


26 ____ Remove personal protective equipment, 

carefully cleaning any items contaminated 

during the discharge process. 

28 ____ Leave the transfer point. 




Appendix 3: Guidelines for the Unloading of Rail Tank Cars 

(A Suggested Checklist) 

This appendix contains guidance for off-loading rail tank cars into storage tanks. Because of variations in the 

configuration of a customer’s facilities, the specific activities involved, or the sequence in which they are 

conducted, may differ from that described in this appendix. 

Toluene Diisocyanate is typically shipped in DOT 111A100 W1, 20,000-gallon rail tank cars that normally 

have baked phenolic-lining and external insulation. 

U.S. Department of Transportation regulation 49 CFR § 174.67 requires that throughout the entire period of 

unloading, and while the rail tank car has unloading equipment attached, a qualified person must attend the 

rail tank car unloading process to ensure safety. The following satisfy DOT attendance requirements: 

• Physical on-site attendance by a person who is alert and has an unobstructed view of the unloading 

operation. 

• A signaling system that includes surveillance equipment (television monitors and video cameras) with 

remote shut-off equipment. This equipment must be monitored at all times either in the immediate area 

of the rail tank car or from a remote location “within the facility.” 

• A signaling system that includes sensors that provide immediate notification of a system malfunction 

(e.g. pressure reduction, leakage, hose or line rupture, and detection of minute levels of fumes or vapors) 

or other emergency so that, if warranted, the product flow may be immediately halted. 


Appendix 3-1



Suggested Checklist for Rail Tank Car Unloading 

1 ____ Refer to the manufacturer’s Material Safety Data Sheet (MSDS) and technical literature for further 

information. 

2 ____ Spot rail car in a level position 

3 ____ Chock wheels 

4 ____ Set derail and hand brake 

5 ____ Post blue “STOP - MEN AT WORK” or “STOP - TANK CAR CONNECTED” sign on tracks 

6 ____ Inspect rail car to make sure it is equipped with the following: 

• equalization/nitrogen valve 

• 2" top unloading valve 

• pressure relief valve 

• verify dome bolts are tight 

• verify that seals are unbroken 

7 ____ Verify that the proper car is on the unloading spot. Carefully check the contents shown on the bill 

of lading or other documented means (for example: supplier’s certificate of analysis) to verify that 

the proper product is being offloaded. 

8 ____ Check rail car placard for proper identification number (for TDI, this number is “2078”) 

9 ____ Record initial level on TDI storage tank to verify that it has enough capacity for the entire contents 

of the car. 

STORAGE TANK LEVEL: _________ lbs 

10 ____ Check the rail car for the required transfer temperature. 

• the temperature of the contents can be adjusted by circulating steam or hot water through 

the car’s external heating coils. 

• consult the supplier if TDI has been frozen. (TDI freezes at approximately 55ºF.) 

11 ____ Check for the required pressure inside the rail car. 

• if the nitrogen pad has leaked out, contact supplier for further instructions. 

12 ____ Check to ensure that an adequate amount of TDI neutralizer (used for spill cleanup) is available in 

the immediate area. If necessary, make an additional neutralizer batch following the instructions in 

Addendum 5, Appendix 11. An emergency spill cart should be available in the immediate area. 

13 ____ Locate the following: 

• safety shower and eyewash 

• telephone or intercom 

14 ____ Put on personal protective equipment that has been tested and found impervious to TDI 

(see API technical bulletin AX-179): 

• appropriate respiratory protection 

• chemical protective suit 

• chemical protective gloves 

• chemical protective boots 





15 ____ Make sure entire unloading operation is attended as required by 49 CFR § 174.67. It is 

recommended that two operators be available. 

For Pump Unloading: 

16 ____ Make sure all rail car valves are closed and carefully remove the outlet caps or plugs. 

17 ____ Connect a 2-inch hose made of a material suitable for transferring TDI, such as Teflon ® 

fluorocarbon or Viton ® fluoroelastomer from the rail car unloading valve to the 2-inch fitting of the 

unloading line pump. 

18 ____ Connect the 2-inch hose from the rail car vapor exchange connection to the vapor exchange line 

from the storage tank. 

19 ____ Open the valve at the pump and the rail cars unloading valve. 

20 ____ Allow the rail tank car pad pressure and liquid head to prime the suction side of the unloading 

pump. 

21 ____ Open the valves on the vapor exchange line and the rail car vapor valve. 

22 ____ Start the pump and operate until the rail car is empty as indicated by the movement in the 

unloading line hose and drop in gauge pressure. 

23 ____ Turn the pump off and then close the unloading line valves. 

24 ____ Blow the lines with nitrogen or dry air and then close the vapor exchange line valves. 

25 ____ Disconnect the unloading and vapor exchange hoses, and replace the caps and plugs on 

pipelines and hoses. Use a suitable tool to tighten all plugs and caps. 

26 ____ Remove personal protective equipment. 

For Pressure Unloading: 

16 ____ Make sure all rail car valves are closed and carefully remove the outlet caps or plugs. 

17 ____ Connect the stainless steel or either Teflon ® fluorocarbon or Viton ® fluoroelastomer hose to top 

unloading valve on the rail car. 

18 ____ Use a 1-inch hose to connect a 35-50 psig pressure supply of oil-free, dry air or nitrogen (with 

dew point of -40° F) to the rail car pad connection. 

19 ____ Pressurize Railcar with 35 psi maximum nitrogen or dry air and verify that it does not leak. 

20 ____ Open the storage tank vent valve to a suitable vent gas treatment system. 

21 ____ Open the valves in the unloading line to the storage tank. 


Appendix 3-3




22 ____ Open the rail car unloading valve to start the flow of material to the bulk storage tank. 

23 ____ Leave the valves in the open position until the receiving tank is full or the rail car is empty as 

indicated by the movement in the unloading line hose and drop in gauge pressure, and 

immediately shut off the air or nitrogen supply to the rail car. 

24 ____ Ensure a positive pad pressure of at least 10-psig remains on the empty rail car. 

25 ____ Close 1-inch air/nitrogen valve on the car, bleed and then disconnect the air/nitrogen hose from 

the rail car. 

26 ____ Close the valve in the receiving piping and the 2-inch unloading valve on the rail car, bleed and 

then disconnect unloading hose. Replace all caps and plugs on the pipes, hoses and rail car 

outlets. Use a suitable tool to tighten caps and plugs. 

27 ____ Remove personal protective equipment. 

After Unloading: 

1 ____ Ensure all valves on the car are closed, all closure caps and plugs are installed wrench tight and 

____ all caps and plugs are secured to the car with chains. 

2 ____ Ensure the top valve cover hatch is closed and the securement pin is installed. 

3 ____ Ensure the manway bolts are secure. 

4 ____ Ensure there is no product residue on the top or sides of the car. 

5 ____ Remove chocks. 

6 ____ Remove blue flags. 

7 ____ Lower derail. 

8 ____ Confirm that all obstacles are clear of the rail tank car and that the car is ready to move. 




Appendix 4: Guidelines for the Inspection of Intermodal Tank 

Containers (A Suggested Checklist) 

This appendix contains guidance for inspecting Intermodal Tank Containers (ISOTainers). Because of 

variations in the configuration of a customer’s facilities, the specific activities involved or the sequence in 

which they are conducted may differ from that described in this appendix. 

U.S. Department of Transportation regulation 49 CFR § 174.67(i) requires that throughout the entire period of 

unloading and while unloading equipment is attached, a qualified person must attend the intermodal tank 

container unloading process to ensure safety. The current DOT attendance requirements demand “physical 

on-site attendance by a person who is alert, is within 25 feet and has an unobstructed view of the unloading 

operation.” 

Cargo Tanks used for the transport of MDI must meet the design and construction requirements of the US 

DOT. When MDI is shipped in a DOT specification container permitted by 49 CFR Part 173, it must conform 

to the applicable design specifications in Part 178. 


Appendix 4-1



Suggested Checklist for Intermodal Tank Container Inspection 

Pre-Loading Inspection 

Frame 

1. ____ Corner Post 

2. ____ Cross Members 

3. ____ Bottom Side Rails 

4. ____ Top Side Rails 

5. ____ Front/Rear Bottom Rail 

6. ____ Front/Rear Top Rail 

7. ____ Diagonal Brace 

8. ____ Gusset 

9. ____ Corner Protection Plate 

10. ____ Stiffener 

11. ____ Ladder 

12. ____ Walkway 

13. ____ Tank Mountings 

14. ____ Painted Surfaces 

Tank Barrel 

1. ____ Cleaned 

2. ____ Reload 

3. Last Contained ____________________________ 

Tank Barrel Accessories 

1. ____ Air Inlet Valve 

2. ____ Top Discharge Valve 

3. ____ Vapor Valve 

4. ____ Bottom Discharge Valve 

5. ____ Valves Identified 

6. ____ Blind Flanges 

7. ____ Gaskets 

8. ____ Remote Trip Cable 

9. ____ Manway 

10. ____ Pressure Indicator 

11. ____ Temperature Indicator 

12. ____ Spill Box 

13. ____ Safety Relief Valve 

14. ____ Rupture Disc 

15. ____ Both 

16. ____ Placard holders 

Cladding 

1. ____ Good Repair 

2. ____ Free of Corrosion 

3. ____ Product Spillage 

4. ____ Joints 

Markings 

1. ____ Missing 

2. ____ Legible 

3. ____ Unnecessary Markings 

4. ____ Proper Shipping Name 

5. ____ Document Holder 

6. ____ CHEMTREC Placard (800-424-9300) 

Data Plate 

1. ____ Periodic Inspection (5 yrs) 

2. ____ Visual Inspection (2.5 yrs) 

Loading Information 

1. Container Last Contained 

__________________________________________ 

2. Quantity to Load ________ 

3. Heat to While Loading ________ 




Suggested Checklist for Intermodal Tank Container Inspection 

4. Customer Temp Specs ________ 

5. Storage Tank Loaded From 

__________________________________________ 

6. Temperature of Storage Tank ________ 

7. Tank Level Before Loading ________ 

8. Tank Level After Loading ________ 

9. Time Loading Started ________ 

10. Time Completed ________ 

11. Commodity Outage (2% min) by: 

Meter ______ Scale Ticket ______ Other ______ 

12. Container Minimum 80% Full ________ 

Post Loading Inspection 

1. ____ Plant Fittings & Gauges Removed 

2. ____ All Valves Closed, Flanged, and Free 

of Leaks 

3. ____ Dome Closed and Properly Secured 

4. ____ Spill Dam Area Clean 

5. ____ Nitrogen Warning Label Affixed 

6. ____ Product Bulk Tag Affixed 

7. Container Padded to ________ lbs. 

8. Pressure Held for ________ minutes 

9. ____ Placards Affixed (all four sides) 

10. UN No. ________ 


Appendix 4-3




ALLIANCE FOR THE 

POLYURETHANES 

INDUSTRY 

A BUSINESS UNIT OF THE AMERICAN PLASTICS COUNCIL 

Document Reference Number: AX-188 

Note: The principal purpose of these guidelines is to provide information about the hazards, or potential hazards to 

health and safety associated with the transportation, handling, and disposal of toluene diisocyanate (TDI). 

The information herein is offered in good faith and is believed to be accurate and reliable as of the date of publication, 

however, it is offered WITHOUT WARRANTY, EXPRESS OR IMPLIED, AS TO MERCHANTABILITY, FITNESS FOR A 

PARTICULAR PURPOSE, OR ANY OTHER MATTER. 

Published by: The Alliance for the Polyurethanes Industry, a business unit of the American Plastics Council 


1300 WILSON BOULEVARD 

ARLINGTON, VA 22209-2321 

703.741.5656 FAX 703.741.5655 

www.polyurethane.org www.plastics.org

TDI Transportation Guidelines - Polyurethanes - American ...

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