You Need to Know about Salvage Drums & New Packaging Regulations
10 Things You Need to Know about Salvage Drums:
Meeting the challenges of modern packaging regulations can be difficult for shippers. The following practical information can help take the mystery out of Salvage Drums and Overpacks.
1) What is an Overpack? An Overpack is defined in US Department of Transportation regulations 49 CFR 171.8 “Definitions”: “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.” This literally means that an Overpack is a bigger container into which a smaller one may be placed. There are many reasons for this, ie, for protection in shipping, for convenience, or just to consolidate packages.
Note that the material of construction or the type of container is not mentioned, because an Overpack could be almost anything. Consider the shipment of goods packaged in cartons and packed in cases, such as hardware items or dry goods items. The cardboard case into which smaller cartons of product are loaded constitutes the use of an Overpack (the outer case). Or consider the shipment of several boxes stretch-wrapped on a pallet, which also constitutes an Overpack. The word “Overpack” is really just a generic term as can be seen from the regulatory definition above. But Overpack can also mean much more. An Overpack Drum is simply a larger container to hold a smaller one.
2) Is there a difference between an Overpack and a Salvage Drum? YES. It is accurate to say “All Salvage Drums are Overpacks, but not all Overpacks are Salvage Drums”. They may look the same or similar, but are different in their application because of Pressure Test performance prescribed by regulations. Salvage Drums are also single trip containers.
3) Why do Salvage Drums and Overpacks look the same? Salvage Drums and Overpack Drums qualify under almost exactly the same performance requirements in the UN “Transport of Dangerous Goods” and US Department of Transportation regulations, which prescribe certain qualification tests for generic drums, including overpacks, and for Salvage Drums. There are size/volume limitations on containers, and both Overpacks and Salvage Drums are required to pass certain “Stack” and “Drop” Tests, based upon the “Packaging Group” (or hazard class) that the container will be qualified for.
4) What’s the big deal about UN Hazard Classes? The UN Hazard classes are ranked I, II, and III with I being the most hazardous group. These classes are designated by the markings “X”, “Y”, or “Z”. The higher the hazard class, the more severe is the performance required in the tests. For instance, the drop test height for Packing Group III is 0.8 meters while the drop test height for Packing Group I is 1.8 meters (essentially the difference between a 2.5’ drop height and 6’ drop height).
The definitions of container types and performance requirements can be found in the UN regulations at Chapter 6.1 “Requirements for the Construction and Testing of Packagings”. This Chapter also calls out the additional Pressure Test required for a Salvage packaging (approximately 5 psi).
5) So what qualifies as a Salvage Drum? Salvage Drum is defined in US DOT regulations at 49 CFR 173.3 in the following critical ways:
a) Must meet or exceed UN performance requirements and be marked for Packing Group III or higher.
b) Must pass a 3 psi pressure test.
c) May not exceed volume or capacity limits.
d) Must be marked with the specific words “Salvage” or “Salvage Drum”.
So, a Salvage Drum is an Overpack because:
1) It meets the definition (a big container into which a smaller container may be placed) in US DOT regulations.
2) It passes all the UN Performance Tests required by US DOT regulations and is marked accordingly.
3) It meets the prescribed volume and capacity limitations (119 gallons maximum, 880 lbs max net mass) defined in the UN regulations.
BUT A SALVAGE DRUM MUST ALSO MEET THESE EXTRA CRITERIA:
4) Passes the required pressure test.
5) “Salvage Drum” labeling.
6) Well, why is it important to use a Salvage Drum instead of an Overpack Drum? The US DOT regulations (see 49 CFR 173.3 c) define the use of a Salvage Drum specifically for: “Packages of hazardous materials that are damaged, defective, or found leaking and hazardous materials that have spilled or leaked may be placed in a metal or plastic removable head salvage drum that is compatible with the lading and shipped for repackaging or disposal…”.
The Salvage Drum is qualified for hazardous materials applications because it passes the required pressure test. An Overpack Drum is not qualified since it does not pass the pressure test and should not be used for hazardous material applications.
7) The drum has the UN numbers on it. Isn’t that all that’s needed?
When referring to listed hazardous materials (see 40 CFR 261 in the US EPA regulations for an itemized listing), the answer is “no”. Why? The UN number is only half the story. All the UN number does is insure that the basic performance requirements can be met. The UN number by itself does not signify Salvage Drum qualification.
The UN number simply tells the user:
- What package type it is.
- What Packing Group (hazard class) the package is authorized for.
- What load capacity is allowed.
- That it is qualified for Solids (S) or Liquids.
- Year of manufacture.
- Country of origin.
- Who the manufacturer/certifier is.
8) What happens when a spill occurs? The user can’t tell in advance what is going to spill or leak. Drum type needed will be determined by two (2) things:
1) Is the stuff a listed hazardous material in US EPA regulations? (Do I use a Salvage Drum or not?)
2) Is the stuff corrosive (Do I pick polyethylene or steel?)
Since the shipper is responsible for assuring that the material is shipped in conformance with regulations, and the type of material spill can’t be predicted in advance, ask yourself if you want to risk major liability for your company. Which product protects your company? A Salvage Drum or merely an Overpack? Clearly the wise choice is the Salvage Drum.
9) OK, how do I confirm that the product I want to buy is a Salvage Drum? Ask the supplier. Request a copy of the labeling to be sure you get a container with the right performance characteristics, and that the labeling states “Salvage Drum”. Demand a copy of the Qualification Certificate. Each self-certifying manufacturer or certification agency is required to keep and maintain all the test records for the packagings, as well as publish a Qualification Certificate for each packaging. Your supplier will have these on file (and so should you) to assure package performance qualifications, markings, and permitted uses.
10) What specific Salvage Drum features should I insist on? The absolute essentials are:
- New and unused
- Salvage Drum labeling
- Chemical compatibility
- Fast on/off closure
- Ease of use: requires no special tools to open and close
- Package qualification certificate
- Reputable source - EnSafeco LLC
New Packaging Regulations Affect HazMat Shippers
Meeting the challenges of today’s packaging regulations can be difficult and time consuming for shippers. And it keeps getting tougher to stay current with packaging regulations. New federal regulations are affecting domestic and international shippers of hazardous materials. And then there is the continued turnover in shipper personnel in today’s job market, which creates a never-ending demand for knowledge training and a constant drain on company resources just to keep up and stay current. These issues and more seem to lead to confusion on the part of shippers everywhere about what types of containers are appropriate for use with hazardous materials, how to verify that the selected container is acceptable for use with a particular waste stream, and so on. For example, something as simple as container closure procedures can turn into a major headache without the proper information. Container closure instructions are not generic, and while at first it may seem a simple matter of common sense on how to close a package, there is more to it than meets the eye.
Container closure is particularly important to public safety and especially for all those involved in the transport, handling, and disposal or reclamation of hazardous materials. Effective and complete container closure in accordance with package qualification is critical to preventing leakage of hazardous materials in transport. The US Department of Transportation considers container closure so critical to transport safety that it has made the topic an important part of the newly reformatted and enhanced US DOT regulations. These enhancements, which became effective 10-1-2004, makes all shippers of hazardous materials responsible for strictly following the manufacturer’s closure instructions that accompany all DOT and UN marked packagings (reference Title 49, Code of Federal Regulations, Section 178.2c). Significantly, shippers are required under the regulations to assure that proper closure procedures have been followed. DOT even goes one step further by suggesting that shippers incorporate verification of container closure in their operating procedures prior to offering closed containers for shipment.
We could all likely agree that training, good procedures, and follow up are essential to success in any situation, but we might have to look hard to find an area of packaging operations that has had less training emphasis than closure and closure verification as a feature of health, safety and security responsibilities. Understandably, there are many potential interpretations of these new requirements, but the one sure and certain way that exists for shippers to virtually guarantee their compliance, to reduce potentially dangerous transport conditions and reduce potential liability is to obtain, maintain, and make it everyone’s responsibility to follow the manufacturer’s closure instructions for each package or packaging in use.
How do closure instructions really affect hazardous material shipment? Take Salvage Drums for instance. Salvage Drums are probably the most recognized specialty container in the hazardous material-shipping arena. But do the shipper’s personnel really understand what a Salvage Drum is and how to properly use and close them? It’s their business to understand, because the shipper is legally responsible and liable for assuring that all packages offered for transport are selected, used, labeled, and closed in accordance with all the applicable regulations. Following manufacturer’s closure instructions is vitally important to package performance and transport safety in critical hazardous material shipments. The ease of use of a © ENPAC, LLC 2012 particular closure may make one packaging more desirable to a shipper than another. For instance, a screw-top Salvage Drum which requires no special tools to close may be better suited for a shipper’s operations due to the personnel costs and time savings when compared to a similar container with another type of closure, a bolt-ring for instance. Without proper closure, however, the shipper may be offering hazardous materials that can leak in transport and cause further contamination and damage. Not the least of our collective concerns, of course, is the risk to human life.
Salvage Drums may perhaps be best understood by what they aren’t. For example, despite their looks and our tendency to think of them as such, Salvage Drums aren’t simply just oversized trashcans. Salvage Drums are actually specialized containers engineered, designed, manufactured, and tested specifically for transport of dangerous goods that are either damaged, leaking, or have spilled. The closures have been designed for just such purposes and to provide safety and security in transport of hazardous materials. Salvage Drums, like many other types of containers, will have a UN number embossed on them, and perhaps even applied to their product label. Again, this in-and-of-itself is not unusual and applies to many other types of containers. The presence of a UN mark does not guarantee that any package with such a mark meets the necessary requirements of a Salvage Drum. These requirements are clearly and concisely spelled out in Federal and International regulations (reference 49CFR173.3c). Salvage Drums for example are required to have the words “Salvage” or “Salvage Drum” embossed on them and/or applied by the manufacturer on a label. Only by following the proper instructions for container closure can the shipper be certain that the packages being offered for transport are actually closed in conformance with all performance objectives for the container. Does your packaging have these markings and important statements present when delivered by the manufacturer or your local supplier? Can you verify package closure, visually or otherwise?
Salvage Drum status and performance is contingent upon being able to successfully close the packaging. This is verified and certified to the shipper and to the public authorities such as US DOT through a Packaging Qualification Notice prepared by each manufacturer of Salvage Drums and updated periodically. This qualification document should be on file, and up-to-date at each shipper’s location where Salvage Drums are offered for transport. Does your packaging have a Qualification Notice? Salvage Drum operation and closure is conveyed to the shipper once again through a written set of closure instructions. These may include diagram(s) and recommended tools that are helpful in accomplishing the task of completing and verifying container closure. Some packaging need no special tools other than a 2x4 or a shovel handle. The Closure Instructions for a packaging are prepared by each package manufacturer and should be included with each delivery of packaging. Does your packaging have a set of Closure Instructions to allow the user to comply with US and International Packaging Regulations and requirements?
Shippers should make it a priority to always be up-to-date on packaging regulations and on package documentation. This helps the shipper to avoid costly, and potentially dangerous, misapplication of packaging. Shippers should insist on maintaining current manufacturer data, certifications, and instructions for all packaging from outside suppliers of hazardous material containers, such as Salvage Drums. For more information about packaging for hazardous material applications, contact the US Department of Transportation, or your local supplier or the manufacturer of hazardous material packaging’s used in your operations. Shippers can avoid possible penalty assessments for non-conforming shipments through closure verification. Be safe. Follow all package closure and use instructions as well as all state, federal and international regulations and requirements. Good shipping!