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The Truth About Salvage
Drums
| There is confusion in the marketplace
regarding Salvage Drums. The term “Overpack” has
become synonymous with “Salvage Drum” in recent
years and there are several new products on the market, which
look like Salvage Drums, but are not. |
What is a Salvage Drum? |
| Salvage Drums are designed to contain
packages of hazardous materials that are damaged, defective,
or found leaking. The drums are regulated by the Department
of Transportation (DOT) under 49 CFR 173.3 (c). If a company
or shipper has a leaking package of hazardous material, sorbents
or rags used on a spill or leak, and they wish to ship them
across public roads, they must use a Salvage Drum under the
restrictions of 173.3 (c). The Salvage Drum is larger than the
leaking package allowing the leaking package to be placed inside
the Salvage Drum for safe shipment to a disposal or treatment
facility. The Salvage Drum must be compatible with the lading
in the leaking package. Shipments that do not follow the DOT
Hazardous Materials regulations are shipping illegally and could
face fines, typically $250.00 - $25,000.00 per violation, levied
by the DOT.
Salvage Drums can be made of steel, polyethylene,
aluminum or metal and must pass, at a minimum, standard UN
performance requirements for drums shipping solids as well
as a 3 psi air leakproof test. If a drum meets the requirements
as stipulated by DOT under 49 CFR 173.3 (c), then it is to
be marked with the appropriate UN markings, proper shipping
name of the material, name and address of the consignee, and
the words “Salvage Drum.” It is illegal to omit
these markings from Salvage Drums prepared in accordance with
173.3 (c). |
What is an Overpack? |
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An Overpack is an enclosure used by a single
consignee to provide protection or convenience in handling a
package, or consolidate two or more packages.
An Overpack is used to contain a smaller non-leaking package.
The integrity of the inner package has not been breached and
the performance of the entire package still meets DOT requirements.
The DOT does not view an Overpack as a Salvage Drum. |
Why is there confusion between Overpacks and Salvage Drums? |
| Traditionally, many manufacturers have referred
to Salvage Drums as “Overpacks.” So the industry
has become more familiar with the term Overpack than Salvage
Drum and believes that all Overpacks must be Salvage Drums.
This is an incorrect assumption. Recently some manufacturers
have been offering drums that look like Salvage Drums but refer
to them as “Overpacks.” Unless your employees or
buyers are very sophisticated on the differences between Overpacks
and Salvage Drums under DOT regulations, they may unwittingly
purchase these Overpacks believing they are buying drums they
can use for Salvage Drum applications. If Overpacks that look
like Salvage Drums cost less than Salvage Drums that could be
the first tip that the Overpack may not meet the performance
standard of a Salvage Drum. |
What is my liability if I use or sell an Overpack that is
not qualified as a Salvage Drum for a Salvage Drum application? |
| The DOT holds manufacturers responsible to properly
design, test and mark the UN/DOT regulated drums and produce
them to a standard that insures performance compliance. Distributors
should not sell a drum for a purpose or regulation that it does
not meet. Finally, the actual shipper must be knowledgeable
enough to use the regulated drums in accordance with the manufacturer
instructions and DOT/UN regulations. The manufacturer, distributor
or shipper can be held liable if they do not meet their obligations
under the DOT/UN regulations. |
Can “used” Salvage Drums be reused? |
If used more than once, Salvage Drums are
subject to the requirements of 173.28. They must be leak tested,
and if they show evidence of a reduction in integrity, they
must be reconditioned. Salvage Drums that comply with these
requirements may be reused or resold. If they have been reconditioned,
the reconditioner must mark them. There are other aspects
to reconditioning including minimum wall thickness and age
of the unit. If you have an opportunity to purchase and use
recycled Salvage Drums, make sure they have been retested,
certified and marked properly to avoid the risk of non-compliance
with DOT regulations in the interest of saving a few bucks. |
What should you use for Spill Kit Containers – Salvage
Drums or Overpacks? |
The most logical choice for a Spill Kit container
would be a Salvage Drum. While you could save a few dollars
buying an Overpack or an economy type container, when you
have a spill and start using the sorbents, that drum will
not qualify as a Salvage Drum should you need to ship off
the sorbents used in a spill clean-up. Even worse, if you
place a leaking package and used sorbents into the Overpack
or economy type container, you will need to buy a Salvage
Drum large enough to place the container, leaking package
and sorbents into for shipping. Buying a Salvage Drum for
your Spill Kits initially insures that when you have a leak
or spill, the Spill Kit you used to hold the sorbents prior
to use, will also allow you to ship off the leaking packages
and used sorbents for treatment, disposal and recycling. Instead
of buying an Overpack for the Spill Kit, then a Salvage Drum
for the clean-up, you will save money and effort by using
a Salvage Drum as your Spill Kit.
Remember, Overpacks overpack non-leaking packages for shipment,
Salvage Drums overpack leaking packages and sorbents for DOT
compliant shipments. |
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