Enware and Enpac guidelines on salvage drums and overpacks
Meeting the challenges of modern regulations governing packaging and handling of hazardous materials can be difficult.
A wide range of industry groups, and the shippers handling their products, need to be aware of expanding international requirements to enhance safety while protecting the environment, the workplace and workers.
A key distinction to be made in this area is the difference between two widely employed hazardous materials containers, salvage drums and overpacks. Their functions often overlap, but they are different in important ways, says Enware Australia, a company that distributes the products of a world leader in secondary containment and spill prevention products, the US Enpac Corporation.
Drawing on clear and internationally relevant guidelines to the differences provided by regulators in the United States and the United Nations (which have been at the forefront of expanding environmental and safety requirements), Enware and Enpac have provided the following practical information to help take the mystery out of salvage drums and overpacks .
What is an Overpack? An Overpack is defined in US Department of Transportation regulations DOT 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.
Is there a difference between an overpack and a salvage drum? It is accurate, 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.
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.
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 (20kPa/ approximately 3 psi).
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:
Must meet or exceed UN performance requirements and be marked for Packing Group III or higher.
Must pass a 3 psi pressure test.
May not exceed volume or capacity limits.
Must be marked with the specific words salvage or salvage drum.
So, a salvage drum is an overpack because:
It meets the definition (a big container into which a smaller container may be placed) in US DOT regulations.
It passes all the UN performance tests required by US DOT regulations and is marked accordingly.
It meets the prescribed volume and capacity limitations (119 gallons/ 450 litres maximum, 880 lbs/ 400kg max net mass) defined in the UN regulations.
But a salvage drum must also meet these extra criteria:
Passes the required pressure test.
Salvage drum labeling.
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 dum 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.
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 ensure 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.
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:
Is the stuff a listed hazardous material in US EPA regulations? (Do I use a Salvage Drum or not?)
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 to 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.
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
Enpac’s Poly-Overpack 95 Salvage Drums from Enware’s Safe-Equip group securely contain a wide range of hazardous materials, including acids, corrosives and solids and liquids including damaged parts.
Part of a wider range of Enpac spill containment, environmental and worker protection products from Safe-Equip Poly-Overpack 95 Salvage Drums combine the usefulness of both overpacks and salvage drums.
The 100 per cent UV protected polyethylene Poly-Overpack 95 Salvage Drums are ideal for hazardous material transport and storage, holding up to 205 litre drums (55 US gallon), with moulded sides for easy gripping and picking up.
The Enpac range is unique in Australasia because it brings together in one system a complete range of solutions to materials handling issues commonly arising across a broad spectrum of industrial applications. These include automotive, building, construction, electrical, food and beverage, government utility, laboratories, manufacturing, materials handling, mining and petroleum, process engineering, primary product processing and transport workshops.
25-Oct-2006