Performance Oriented Packaging Requirments

What Makes a Drum

Drums can be classified as an open head or tight head.- An open head has a removable lid that is secured on the drum with a locking band. Some open head containers have a lug cover that is crimped on.- A tight head is a drum that does not have a removable lid. This drum has fittings in the top which allow for filling and pouring. These fittings vary accordingly to the material of the drum.The standard for 55 gallon steel drum is a steel 2″ and 3/4″ fittings; whereas a 55 gallon Plastic drum has a 2″ plastic buttress and a 2″ plastic NPT.
Drums are manufactured in various materials-here are a few:– Steel
– Plastic
– Fiber
Drums come in a variety of sizes. – The size of the drum varies accordingly to customers request. Such as 5 gallon, 30, 55, 85, 110 etc.
Some drums are certified for hazardous material- Regulated Drums are drums that have to meet a particular UN rating accordingly to the hazardous materials being contained.
– What is a Hazardous Material-A hazardous material is any substance or material that is capable of posing an unreasonable risk to health, safety, and property when transported in commerce.
– Hazardous materials are rather complex- especially when other terms are used to define it, such as hazardous substance, marine pollutants, hazardous waste. It is the shipper’s responsibility to know what the product is classified as. This allows him/her to identify the minimum UN requirement that container has to meet.
– Non-Regulated Drums are drums that do not have to meet a UN number. Some materials are not classified as a Hazardous Material.
How does this effect you?– If you, in the course of your job duties, directly affect the safety of hazmat in transportation, you are considered a hazmat employee. Even though you do not come in direct contact with the hazardous material, you have an effect on the process
Where can you find additional information? -There are numerous books of regulation that you can explore. Here are a few:
– Code of Federal regulations
– HM-181 and HM-126F
– Dangerous Goods Regulations
– Transportation of Dangerous Goods.
– There are several websites you can visit also.

Code of Federal Regulations (CFR)

The Code of Federal Regulations (CFR) is a codification of the general and permanent rules of the Federal Government, which is published in the Federal Register. THe Code is divided into 50 titles which represent broad areas subjected to Federal Regulations. Each title is divided into chapters which usually bear the name of the issuing agency. Each chapter is further subdivided into parts covering specific regulatory areas.Hazardous Materials Regulations (HMR) govern the safety aspects of transportation of hazardous material in commerce. The Hazardous Materials Regulations are administered by the Department of Transportation (DO), and are found in the Code of Federal Regulations (CF), Title 49_ TRANSPORTATION, parts 100 to 177 to 199. These regulations contain detailed instructions on how hazardous materials have to be identified, packaged, marked, labeled, documented, and placard. Shipments no in compliance with the applicable regulations may not be offered or accepted for transportation.Within the regulatory process, the CFR is used to determine packaging that can be used for shipping regulated products, such as flammable, toxic, and corrosive products.

The general requirements in Title 49 CFR 173.24 and the test requirements outlined in TITLE 40 CFR 178.601 are intended to ensure that packaging containing hazardous materials can withstand the normal rigorous conditions of transportation. The test requirements in Title 49 CFR 178.601 are MINIMUM requirements. Each packaging must be manufactured and assembled to successfully pass the prescribed test and conform to the general requirements of Title 49.

It is the responsibility of the person offering a hazardous material for transportation to ensure that such packaging are compatible with their lading and comply with the standards and test requirements in the CFR.

The DOT monitors all containers manufacturers and shippers of hazardous materials. Manufacturers and shippers are routinely inspected for compliance in such areas as record keeping and container performance.

If a shipment is found within the transportation system not to be in compliance with the applicable regulations, it will be delayed. In addition, non-compliance with the applicable regulations can subject the shipper, forwarder, and carrier, as appropriate, to Civil Penalties- fines up to 25,000 per violations or Criminal Penalties – finds, imprisonment of up to fives years, or both.

A civil Penalty is generally imposed when hazardous materials regulations are not followed. This can result when something is not done that the regulations require to be done, such as marking the proper name on a package, or when something is done that the regulations prohibit such as putting a placard on a vehicle that does not contain hazardous materials.

A Criminal Penalty is imposed when the hazardous materials regulations are violated intentionally. A typical violation would be offering a hazardous material package requiring a POISON label for shipment without the label because the carrier will not accept POISON label because the carried will not accept poison labeled packages.

U.N. Container Markings

Container markings referenced
by corresponding letter designation
and description
A.) Manufacturer’s IdentificationB.) U.N. Symbol Not: May also be UN2 - Performance Oriented Packaging RequirmentsC.) “1” designation for drum.D.) “A” designation for Steel; “H” designation for Plastic. “G” for Fiber

E.) “1” designation for Tight Head; “2” designation for Open Head.

F .) Packing Group: “X” designates Groups I,II, III
“Y” designates Groups II, III
“Z” designates Groups III

G.) Solids must show max gross weight in kilograms and “S” i.e. 30/S. Non0viscous liquids must show specific gravity and max test pressure in kPA. (Note: If specific gravity is 1.2 or less it may be eliminated.) Viscous liquids must max gross weight in kilograms.

H.) Year of manufacture for Steel; month and year for Plastics. (Month may appear elsewhere on bottom of Plastic container.

I.) Country of MFG. and Competent Authority.

J.) Mfg’s name, initials, or “M” registration number as registered with Competent Authority.

K.) Container size millimeters (reusable containers only)

L.) Container/cover gage – capacity in gallons

1. Drum
2. Wooden Barrel
3. Jerrican
4. Box
5. Bag
6. Composite packaging
7. Pressure receptacle
9.4.6 The following capital letters should be used for the types of material:
A. Steel ( all types and surface treatments)
B. Aluminum
C. Natural Wood
D. Plywood
F. Reconstituted wood
G. Fibre board
H. Plastic Material
L. Textile
M. Paper, multi wall
N. Metal (other than steel or aluminum)
P. Glass, porcelain or stoneware
9.4.7 The following types and codes of packaging are assigned:
Kind Material Category Code Paragraph
1. Drums A. Steel non-removable head
removable head
B. Aluminum non-removable head
removable head
D. Plywood 1D 9.6.4
G. Fibre 1G 9.6.6
H. Plastics non-removable head
removable head

Definitions: Clarification of Terminology

UN Chapter 9: General Recommendations on the Transport of Dangerous Goods. (Orange Book)
HM-181: Docket # assigned to UN Recommendations in US before acceptance as 49 CFR.
CFR 49: Code of Federal Regulations Title 49 (DOT Hazardous Materials Regulations).
DOT: Department of Transportation. US Regulatory Agency for Transportation,
POP: Performance Oriented Packaging. Emphasis behind UN Recommendations.
Specific Gravity (S. G.): Ratio of density of a substance in relation to water.
Vapor Pressure: Pressure variation within closed container attributed to change in temperature of medium and/or environment
Hydrostatic Pressure: Water pressure measured in kPA (kiloPascals)
COG Drop: Center -of-gravity drop. Concentrates entire mass of pail on chime.(October 1, 19920
Weight designation for Solids: Shown in kilograms (kg) followed by “S” I.E. 1 kg = 2.2 lbs.
27kg = 60 lbs.
36kg = 80 lbs.