Significant changes from CAN/CGSB-43.146-2002 to CAN/CGSB-43.146-2016

The Canadian General Standards Board updated the CAN/CGSB-43.146 standard. Since the last revision of this standard 14 years ago, no less than eight editions of the Recommendations on the Transport of Dangerous Goods, Model Regulations (UN Model Regulations) have been published. The CAN/CGSB-43.146-2002 was based on the 11th edition and the CAN/CGSB-43.146-2016 is based on the most up to date edition of the UN Model Regulations (19th edition).

This document summarizes the most significant changes to the standard that are applicable to IBC manufacturers. Not all changes to the standard are covered here.

It is the responsibility of the IBC manufacturer, IBC leak test and inspection facility or IBC user to read and understand the sections of the standard that are applicable to their respective activities, to ensure that they are aware of all the changes.

For IBC Manufacturers

It is your responsibility as an Intermediate Bulk Container (IBC) manufacturer to read and understand the sections of the standard applicable to you to ensure you are aware of all the changes.

Compliance marking (section 5)

“W” Marking

The “W” marking is no longer required for the following cases:

  • Mobile IBCs that have a maximum capacity between 3000 L and 5000 L. These mobile IBCs will be restricted to transporting flammable liquids (Class 3) dangerous goods of packing group III;
  • Mobile IBCs with multiple compartments;
  • Composite IBCS with multiple inner receptacles; and
  • Non-proportional reductions of mobile IBCs (please refer to the standard for specific conditions).

The “W” marking may still apply to other designs manufactured to a different specification if the Director is satisfied that the IBC is equivalent to an IBC that conforms to the standard.

Maximum Permissible Stacking Load and Non-Stackable IBC Symbols

The inclusion of the maximum permissible stacking load and non-stackable IBC symbols is required to harmonize the domestic regulations with the UN Model Regulations. These symbols have been mandatory in international transport for all IBCs manufactured after January 1, 2011.

 


Figure 1: Maximum permissible stacking load symbol


Figure 2: Non-stackable IBC symbol

 

Construction (section 6)

Mobile IBCs

The design of mobile IBCs is considerably different from the design of any other metal IBCs.  To acknowledge this, mobile IBCs now have their own construction requirements.
The two most noteworthy changes are:

  • Bottom openings: These openings were prohibited in the 2002 edition of the standard. The 2016 edition allows them under certain conditions.
  • Multiple compartments: The new standard will allow the design of mobile IBCs with multiple compartments under certain conditions.

Other new construction requirements for mobile IBCs relating to stability of the means of transport, gauging devices, piping and baffles have been added.

Testing (section 7)

Vibration Test

The requirement for vibration testing now only applies to IBCs designed to hold liquids (31 Code IBCs).  Please note that an error has been found in clause 7.13.3b) of the 2016 edition in regards to the referenced vibration test method for mobile IBCs.  The referenced test method should have remained ASTM D999 Method B. Laboratories conducting this test will be informed of the error and a corrigenda will follow.

Modifications without retesting (section 8.1)

New options have been added to the modifications that are permitted without retesting, especially for mobile IBCs. It is strongly suggested to review this section carefully prior to submitting an application for design registration.

Production testing (section 9)

The requirement to perform the leakproofness test during production has been expanded to apply to Code 21 IBCs, double-walled mobile IBCs and mobile IBCs with multiple compartments in additions to Code 31 IBCs for which they were already required.

Quality Management Systems (QMS) (section 10)

This section has been modified to take into account remanufacturers that only perform cross-bottling activities. Since these facilities are assembling composite IBCs and are not manufacturing any components, their QMS do not require certification by a Registrar.  However, these facilities must adhere to a quality management system where the requirements are largely aligned with ISO 9001.

Transport Canada Registration (section 11)

The way in which Transport Canada issues registrations will change going forward. In the future, when a new registration is issued or an existing one renewed:

  • The certificate will be issued to the manufacturing facility under the number 46-XXX.
  • The certificate will list all the manufacturer’s registered designs in an appendix.  There will be no changes to the compliance markings (UN marking strings) as the design registration numbers will not change (4-XXX).
  • The new certificates will be valid for 5 years instead of the current 3 years.

All current design registrations remain valid until their expiry

This will streamline the application and record keeping processes as all designs held by a manufacturer will be found on the same Certificate of Registration and have the same expiry date. Only one renewal application will need to be submitted and only one Certificate of Registration will need to be documented.

For IBC Leak Test and Inspection Facilities

You are required to submit a revised procedure to maintain the information in your file up to date before the end of the transition period.

Periodic leak test and inspection

The following major changes to the periodic leak test and inspection of IBCs have been made:

  • All sizes of IBCs must be leak tested and inspected, including those under 450L.
  • Mobile IBCs are now required to be leak tested and inspected every 60 months.
  • Lightweight IBCs must be leak tested before each use as opposed to asset IBCs which are still required to be tested and inspected every 30 months. This requirement is stricter than the requirement of the UN Model Recommendations as they do not make a distinction between the two types of composite IBCs (lightweight vs. asset).
 

Figure 1: lightweight IBC


Figure 2: Asset IBC
 

Refer to Annex C of CAN/CGSB-43.146-2016 for additional information.

Periodic leak test and inspection procedure

All IBCs

  • Quality management system (QMS) - The QMS requirements have been expanded and largely aligned with ISO 9001.  It remains that the QMS does not need to be certified by a Registrar.
  • Records of successful leak tests and inspections - This requirement has been modified to make the recording of successful tests mandatory only for metal IBCs (31A, 31B and 31N) as they are the only ones that are required to bear a serial number.

Mobile IBCs

  • Removal from the means of transport - It was not clear in the previous edition that mobile IBCs needed to be removed from the means of transport prior to the inspection. The 2016 edition makes it clear that unless contained in equipment or fully enclosed in a means of transport, mobile IBCs must be removed from the means of transport so that all accessible surfaces are examined for damage or evidence of leakage.
  • Cleaning and internal inspection - These steps are no longer required for mobile IBCs as they are only required to be drained of previous lading before the leak test.  The internal inspection has been replaced by a leak test since the internal inspection of mobile IBCs is often limited due to their designs (small openings, many baffles, etc.).
  • Leak test - This step has been expanded to include mobile IBCs.  It also covers the leak testing of double walls and multiple compartments.
  • Minimum retention period - The minimum period of record retention of successful leak test and inspection of mobile IBCs has been extended to 60 months. This now aligns with the periodic leak test and inspection schedule.

Metal IBCs

  • External Inspection - Every reclosing emergency pressure-relief device will have to be inspected and tested to open at no less than the required set pressure in the standard.

Rigid plastic IBCs and plastic inner receptacle of composite IBCs

  • Shorter period of use - These IBCs are not eligible for the leak test and inspection process if they have reached their maximum prescribed period of use of 60 months past the manufacturing date. 

For Users of IBCs

It is recommended to read the sections of the standard applicable to you to ensure you are aware of all the changes.

Selection and use

Part II of CGSB-43.146 pertaining to the selection and use of IBCs has been revisited and now includes new requirements that need to be met before filling an IBC, when filling and closing an IBC or before offering an IBC for transport.

Two noteworthy changes are:

  • The shorter period of use of rigid plastic IBCs and plastic inner receptacle of composite IBCs -  The 2002 edition implied that, under certain conditions, rigid plastic IBCs and plastic inner receptacle of composite IBCs might be used for up to 10 years after their date of manufacture.  The updated standard sets out a maximum time of 60 months after their date of manufacture to be eligible for re-use, and
  • Visual inspection of all flexible hoses and couplings will be required before filling a mobile IBC.

Certain requirements specific to certain classes of dangerous goods have been removed from this section and added to Annex B, Packing Instructions, instead.

Periodic leak test and inspection

The following changes to the periodic leak test and inspection of IBCs have been made:

  • All sizes of IBCs must be leak tested and inspected, including those under 450L.
  • Mobile IBCs are now required to be leak tested and inspected every 60 months.
  • Lightweight IBCs must be leak tested before each use as opposed to asset IBCs which are still required to be tested and inspected every 30 months.  This requirement is stricter than the requirement of the UN Model Recommendations as they do not make a distinction between the two types of composite IBCs (lightweight vs. asset).
 

Figure 1: lightweight IBC


Figure 2: Asset IBC
 

Refer to Annex C of CAN/CGSB-43.146-2016 for additional information.

Equivalent specification tanks

ULC/ORD-C142.13 mobile refueling tanks manufactured before January 1, 2003 may now be used as equivalent specifications as they have been reintroduced in the 2016 edition of the standard.  As a result, Special Provision 91 of the Transportation of Dangerous Goods Regulations will be repealed once the 2016 edition of the standard is adopted into the regulations.

Packing Instructions

All detailed packing instructions found in Part 2 of the standard have been updated to reflect changes to the 19th revised edition of the Recommendations on the Transport of Dangerous Goods, Model Regulations.

Most noteworthy is the change to Packing Instruction 3 which allows for the transportation of flammable liquids of Class 3 and PG III (such as diesel) in mobile IBC of a capacity of up to 5000L. This relaxation in regards to the capacity does not apply to gasoline or any other flammable liquid of Class 3, PG II.

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