UN/DOT Compliance Drums
Anytime a shipment is transported, either intrastate, interstate, or through foreign commerce, that shipment must be accompanied by the proper documentation and, when necessary, must be shipped using compliant containers. It is the responsibility of the end user/packaging party to ensure that they have created a compliant package.
A good portion of our New Carbon Steel Drums, Plastic Drums, Reconditioned Drums, Composite Drums, and Fiber Drums are UN / DOT compliant. For more detailed information and assistance please give us a call at 865-673-9396.
There are three (3) main hazard classes as defined by the 49 Code of Federal Regulations (CFR). The three classes are as follows:
- Packing Group 1 (PG I) hazard class is Great Danger and is marked on the package as “X”. This is the most dangerous class of materials.
- Packing Group 2 (PG II) hazard class is Medium Danger and is marked on the package as “Y”. These are the materials which are classed as a medium danger.
- Packing Group 3 (PG III) hazard class is marked on the package as “Z” (or may not be marked at all) and is a Minimum Danger. These are the materials which cause no threat to the environment or any human being.
To bear the UN rating, a drum must be tested to meet the requirements of 49 CFR 178.603 Drop Test, 178.604 Leakproofness Test, 178.605 Hydrostatic pressure Test, 178.606 Stacking Test for liquid and solid (as applies), and 178.608 Vibration Standard. 178.607 applies only to bung type wooden barrels therefore is not normally included in UN test reports provided by manufacturers or outside testing parties. Drum manufacturers are required to perform these tests annually, or if the container design has changed.
Drums, or barrels, are marked when manufactured or reconditioned by the manufacturer/reconditioner. The sequence of symbols is typically found on both the bottom and side of a metal container, and normally on the side of plastic and fiberboard drum. The markings can be either painted on the side, or applied on a weather resistant label. Metal drums with a minimum “Y” rating must also bear the marking, along with the thickness of the metal, either embossed or stamped into the metal on the bottom head of the container.
The standard markings for a drum manufactured or reconditioned for use in transporting regulated materials will normally begin with the lower case letters “u” and “n” stacked one on top of the other and enclosed in a circle . This symbol will then be followed by the package identifying markings. Below is an explanation of those markings.
So a container marked 1A2/X300/S/15/USA/M**** would be an open head steel drum for use with medium hazard materials. The weight of the completed package can not exceed a total of 300 kilograms; contents must be solid, year of manufacture, country of origin, and the manufacturer’s identification number or symbol.
Reconditioned containers, as with new, must be marked with the reconditioner’s identification or number, as well as bearing the mark “RL” which stands for “reconditioned” and “leakproof tested”. Reconditioned metal drums rarely bear the same markings as the original markings which the manufacturer had tested to. Also, only certain drums meeting specific criteria can be reconditioned as a DOT approved container. In order to be able to transport using a reconditioned container you should always know the regulations set forth by the Department of Transportation for the material you are packaging for shipment, and you must make sure you are using the correct container for your application. For example,a reconditioned open head carbon steel drum which is suitable for use in storing and transporting certain hazardous materials could be marked as 1A2/Y1.4/100/USA/M****/16/ RL This marking means that the drum is an open head metal drum with a specific gravity of 1.4 liquid. In order to find the maximum mass on an open head drum which is marked for liquids, the formula is as follows:
- Specific Gravity (1.4) times the weight of water (8.22) = 11.51 lbs per gallon
- Pounds per gallon (11.51) times gallon capacity (55) = 633 total volume weight.
Most reconditioned open head metal drums with a DOT rating will be marked with the liquid rating, but can be used for either liquid or solid.
As to the use of open head plastic drums for liquids, slushes, and/or slurries, most open head plastic drums are only rated for solids. They are not tested nor approved for shipment of liquids. When using the plastic open head containers, there should be a liner installed and there should be sufficient absorbent material in the drum to absorb all free liquids. Again, it is up to the filler to know what type container they can or can not legally use in order to ship their product or waste.
7A Type A Compliance Drums
7A Type A compliant drums are UN rated drums that are put through additional testing in accordance with 49 CFR 173.465. This allows for the drums to be used for permissible radioactive materials. The testing necessary for the container to be used as part of a 7A Type A package it must pass, in addition to the tests performed as outlined in the Design Qualification Testing (178.603, 178.604, 178.605, 178.606, and 178.608), the container must meet the applicable tests as outlined in 173.465. Many 7A Type A containers are tested for use with packaging fissile materials as well.
Volunteer Drum cannot certify a package as being a DOT 7A Type A package. It is the responsibility of the end user / packaging party to certify that the package meets all of the applicable requirements. But, we can provide all of the necessary 7A test reports and other material documentation, as requested for applicable drums. It is important to note that in order for a package to meet the required testing, the components can not be changed such as with a different gauge lid or ring than was tested. Any variation from the original design must be retested. As long as the design does not change, the 7A testing is considered valid for the entirety of the manufacturing of that container design. It is also important to mention that the package must be closed according to the manufacturer’s closure instructions. Please feel free to contact us for more information, or you may follow the links provided if you know the manufacturer/reconditioner of your container.
Eagle Lever Latch Ring Drum Closure Instructions
Eagle Screw Top Drum Closure Instructions
New 5 Gallon LifeLatch Closure Instructions
New G-Cube Closure Instructions
Berenfield New Drum Closure Instructions
Reconditioned Closure Instructions
Drum Assembly GSD
Skolnik (SDCC) Closing Instructions
A good portion of our new open head carbon steel drums are 7A Type A complaint, and can be found on our New Carbon Steel Drums page.