Risk Bulletin

Allianz Global Corporate & Specialty

Intermediate Bulk Containers

Rigid Non-Metallic/Composite/Plastic
Recommended Guidelines published by Allianz Risk Consulting

September 2012

Background
The use of intermediate bulk containers (IBCs) inside buildings and not within approved storage rooms pose a significant hazard that should be addressed in loss control evaluations. IBCs are classified as portable tanks by the National Fire Protection Association (NFPA) 30 Flammable and Combustible Liquids Code. They often approximate the size of a pallet unit load, containing anywhere from over 119 gallons (450 L) but not to exceed 793 gallons (3000 L) of liquid. Commonly, they are constructed of either plastic or metal. This bulletin addresses the hazards associated with plastic IBCs, otherwise known by the terms Rigid Non-Metallic or Composite IBCs.

The primary advantage of IBCs is the efficiency in transport and use; moving and storing IBCs is much easier than the equivalent number of 55-gallon drums. IBCs are sometimes called by the generic name tote.

Currently, a conflict exists between DOT allowances and fire codes (such as NFPA). While DOT regulations may allow for shipment of flammable/combustible liquids in such containers, storage of such containers inside buildings is a fire code enforcement issue, not a DOT issue. This is often misunderstood by building and business owners, whose normal response may be that the containers are approved. While IBCs are ideal for the easy transport of flammable/combustible liquids, they pose an extreme storage hazard - even greater than 55 gallon drum storage of the same liquids.
But IBCs also pose a far greater spill hazard than smaller containers; a leak in an IBC could quickly result in a pool fire involving hundreds of gallons of flammable/combustible liquids - a condition that is often unprotectable with automatic sprinklers. The term rigid non-metallic also denotes an allplastic single-wall IBC that could or could not have a separate plastic base, and for which the containment vessel also serves as the support structure. IBCs that have an outer liquid tight metal structure are considered to be metal IBCs or metal portable tanks by DOT.

Rigid Non-Metallic IBCs

The term rigid non-metallic is used to describe intermediate bulk containers that have a plastic vessel that serves as the primary liquid-holding component. This vessel can be enclosed in or encased by an outer structure consisting of a steel cage, a single-wall metal or plastic enclosure, or a double wall of foamed or solid plastic. Where provided with one of these outer structures, they are often called composite IBCs, which is the term used by the US Department of Transportation (DOT) to describe them.

Contact
Craig Kolakowski ARC Manager Inland Marine & Related Property +1.610.772.5974

Photo of an intermediate bulk container (IBC)

NFPA 30 allows only IBCs that meet the requirements of a specific DOT regulation, as well as a United Nations (UN) document (recognized internationally). For protected storage, rigid non-metallic IBCs are required to have been subjected to a standard fire test, such as Underwriters Laboratories (UL) 2368, Fire Exposure Testing of Intermediate Bulk Containers for Flammable and Combustible Liquids, which demonstrates acceptable inside storage fire performance and which is to be listed and labeled. NFPA 30 contains provisions for specific sprinkler protection criteria for rigid non-metallic IBCs. These provisions tables were first introduced in the 2000 edition of NFPA 30, based on a series of fire tests. These tables also specify that they apply to rigid non-metallic IBCs that have been subjected to a standardized fire test that demonstrates the fire performance when IBCs are stacked one or two high and that are listed and labeled as such. Unfortunately, at this time, there is only one manufacturer that makes a UL-listed rigid non-

metallic (plastic) IBC that is fire rated. Its use is very uncommon, due both to cost and to lack of enforcement in this area by Authorities Having Jurisdiction. Fire testing recently conducted in the UK demonstrates that these rigid non-metallic/ composite/plastic IBCs rapidly fail and release liquid (particularly around the valve area) when exposed to fire. This rapid release of liquid results in a fast-spreading pool of burning liquid, which can overwhelm sprinkler protection. All rigid non-metallic/composite/plastic IBCs not loisted and labeled containing flammable or combustible liquids should be considered extremely hazardous. They should be immediately removed from any production and/or warehouse area of discussed with the Loss Control Manager. See the table below for tips to storing IBCs.

Tips for storing IBCs

NFPA 30 allows only IBCs that meet the requirements of a specific DOT regulation, as well as a United Nations (UN) document (recognized internationally). The storage of Class I flammable liquids in composite IBCs is prohibited. Listed composite IBCs may be used for indoor storage of Class II and III combustible liquids of unlimited quantity, but only in specific palletized arrays or rack configurations protected by sprinkler systems with large hydraulic demands-refer to LC Manager. Non-Listed composite IBCs may be used for indoor storage of combustible liquids. This storage, however, is treated as unprotected storage, and the total number of containers, pile size, and pile height are limited. Unprotected storage implies that should a fire occur, the total contents of the fire area may become involved in the fire, regardless of the fire protection features (sprinklers) provided.

An excellent source for information, including a video of testing, is: http://www.hse.gov.uk/research/rrhtm/ rr564/index.htm It is important to note that all metal/steel IBCs do not present the same hazard and can generally be protected with adequately designed sprinkler systems.

Copyright 2012 Allianz Global Corporate & Specialty AG. All rights reserved. The material contained in this publication is designed to provide general information only. Please be aware that information relating to policy coverage, terms and conditions is provided for guidance purposes only and is not exhaustive and does not form an offer of coverage. Terms and conditions of policies vary between insurers and jurisdictions. While every effort has been made to ensure that the information provided is accurate, this information is provided without any representation or warranty of any kind about its accuracy and Allianz Global Corporate & Specialty cannot be held responsible for any mistakes or omissions.