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 leak proof 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?
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.
by Mark Shaw, From the Winter 1998 issue of Environmental Solutions
Product News
Related Dawg® Products
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Poly Overpack Drums & Labpacks
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20
& 30 Gallon Labpacks and Overpacks
Labpack Containers 20, & 30 gallon
Large
Capacity: 180 & 600 Gallon Overpacks
Large Overpacks 180 & 600 gallon
