Bulk Packaging Standards
Pipeline and Hazardous Materials Safety Administration · Mar 16, 1995 · Reference No. 95-0271
Interprets: 49 CFR § 172.330
Reggie’s quick take
A company's question about bulk packaging rules got a set of answers from PHMSA in 1995. The agency said that portable tank rules cover all bulk packagings that meet the portable tank definition, not only DOT-specification and IM tanks. It also said the HMR does not require IBCs to carry a proper shipping name or technical name. For identification numbers, § 172.302 requires marking on bulk packagings, including IBCs, using § 172.332. Bulk packagings under 1,000 gallons need numbers on two opposite sides, and those 1,000 gallons or larger need them on all four sides. Stenciling in place of placards or orange panels is allowed only for multi-unit tank car tanks under § 172.330(a)(2)(ii).
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.
This is in response to your letter of September 2, 1994 regarding requirements for intermediate bulk containers (IBCs), portable tanks, and other bulk packagings.
Your request to add a maximum net mass capacity for IBCs containing solids is under consideration in a response to petitions for reconsideration of the final rule under docket HM-181E. Your additional questions are paraphrased and answered as follows:
Q1. Do all 49 CFR references to portable tanks apply only to DOT specification and IM portable tanks?
A1. No. References in the Hazardous Materials Regulations (HMR) regarding portable tanks apply to all specification IM and non-specification bulk packagings which meet the definition of a portable tank.
Q2. Must IBCs be marked with the proper shipping name and, where applicable, the technical name?
A2. There is no requirement in the HMR to mark an IBC with a proper shipping name or technical name.
Q3. Are there any options for displaying an identification number on an IBC on other than a placard, orange panel, or white-square-on-point configuration?
A3. No. As specified in § 172.302, bulk packagings, including IBCs, must be marked with an identification number as prescribed in § 172.332. This section requires that an identification number be displayed on a placard or orange panel. For materials for which a placard is not prescribed, an identification number may be displayed on a white square-on-point configuration in lieu of an orange panel, as prescribed in § 172.336(b). For bulk packagings of less than 1000 gallons capacity, identification numbers are required to be displayed only on two opposing sides. For bulk packages of 1000 gallons capacity or more, identification numbers must be displayed on all four sides.
Q4. Can § 172.330(a)(2) be interpreted as to permit the stencilling of ID numbers on multi-unit tank car tanks in lieu of displaying the ID number on placards, orange panels or white-square-on-point configurations? Does this hold true in § 172.331 for bulk packagings other than portable tanks, cargo tanks, tank cars and multi-unit tank car tanks?
A4. Section 172.330(a)(2)(ii) permits stencilling of identification numbers on multi-unit tank car tanks only. For other bulk packagings, including portable tanks, cargo tanks, and tank cars, identification numbers must be employed on placards, orange panels, or white square-on-point configurations.
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.