Handling and Testing of a Flexible IBC on a Pallet
Pipeline and Hazardous Materials Safety Administration · Nov 16, 2020 · Reference No. 20-0076
Interprets: 49 CFR § 171.8, 49 CFR § 173.1, 49 CFR § 173.25, 49 CFR § 177.834(a), 49 CFR § 178.1, 49 CFR § 178.801(d), 49 CFR § 178.803
Reggie’s quick take
A company asked whether a flexible IBC (a large bulk bag) that passed testing without being attached to a base pallet can be placed on a pallet, and whether it can be attached to one. PHMSA says yes to placing it on a pallet and yes to attaching it with nails, staples, strapping, or stretch wrap, as long as the attachment doesn't break packaging rules in Parts 173 and 178 and isn't permanent. A permanent attachment would likely be a new design needing more testing. Securement is still required in transport under § 177.834(a). Stretch wrap or strapping used this way is an overpack under § 171.8. Whether extra testing is needed depends on how the bag is attached.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
November 16, 2020
Reference No. 20-0076
This letter is in response to your September 11, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a flexible intermediate bulk container (IBC). You ask several questions regarding the flexible IBC testing and handling requirements when flexible IBCs are transported on pallets in commerce. Specifically, you ask the questions with regard to a flexible IBC that has been successfully tested without securely attaching it to a base pallet.
We have paraphrased and answered your questions as follows:
Q1. You ask whether the container (e.g., the flexible IBC) may be placed onto a base pallet for ease of handling in transport.
A1. The answer is yes.
Q2. You ask whether the flexible IBC may be placed on a base pallet without any means of secure attachment.
A2. The answer is yes; however, for purposes of transportation, packages must be secured. For example, for motor vehicle transportation, any package containing a hazardous material not permanently attached to a motor vehicle must be secured against shifting, including relative motion between packages, within the vehicle on which it is being transported under conditions normally incident to transportation (see § 177.834(a)).
Q3. You ask whether the flexible IBC may be securely attached to a base pallet, via mechanical device nails, staples, strapping, or stretch wrapping.
A3. The answer is yes. Securely attaching the flexible IBC to a base pallet with mechanical device nails, staples, strapping, or stretch wrapping is not prohibited as long as the attachment does not affect compliance with general and specification packaging requirements in Parts 173 and 178 of the HMR, and provided such securement methods do not permanently secure the flexible IBC to a base pallet. In the instance where the flexible IBC is permanently secured to a base pallet, it would likely be considered a new design type subject to further testing.
Q4. You ask whether any of the methods of securing the flexible IBC to a base pallet (e.g., mechanical device nails, staples, strapping, or stretch wrapping) constitute an “overpack” as defined in § 173.25.
A4. The answer is yes. For purposes of the HMR, and as defined in § 171.8, an “overpack” means an enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages. An example of an overpack is a package placed or stacked onto a load board (i.e., a pallet) and secured by strapping, shrink wrapping, stretch wrapping, or other suitable means (emphasis added). Please note that securement methods that would permanently secure the flexible IBC to a base pallet would not be considered an overpack. Permanently securing the flexible IBC to a base pallet would likely be considered a new design type and would require further testing.
Q5. You ask whether the act of securely attaching a flexible “13HX” IBC to a base pallet requires the packaging to be fully tested with a base pallet.
A5. The answer is dependent on certain factors (see answer A3). In accordance with § 178.801(d), the packaging manufacturer must achieve successful test results for the design qualification testing at the start of production of each new or different IBC design type. The service equipment selected for this design qualification testing shall be representative of the type of service equipment that will be fitted to any finished IBC body under the design.
Furthermore, in accordance with § 178.803, flexible IBCs must undergo the vibration, top lift, stacking, drop, topple, righting, and tear tests. Note that flexible IBCs are neither subject to the bottom lift test nor are they subject to the top lift test if not designed to be top lifted. However, as indicated in answer A3, securely attaching a base pallet to the flexible IBC is not prohibited within the HMR, but further testing of the flexible IBC may be required depending on the manner of attachment.
Q6. You ask whether the act of placing a flexible “13HX” IBC on a pallet without attachment to a base pallet requires the packaging to be fully tested with a base pallet.
A6. The answer is no. Also, see answer A5.
Q7. When testing is required, you ask whether the complete suite of tests (i.e., vibration, bottom lift, top lift, stacking, drop, topple, righting, and tear) is required or only the bottom lift test.
A7. See answer A5.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
171.8, 173, 173.25, 177.834(a), 178, 178.801(d), 178.803
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.