Recent questions regarding the use of Salvage Drums to transport dangerous goods that are packed incorrectly or illegally have been addressed by both the US-DOT and the United Nations. Non-Specification, or "Under-Specification" containers that do not show signs of leakage or damage can be legally placed in a Salvage Drum for disposal or repackaging. Addressed by the Committee of Experts at the December 1999 meeting in Geneva, the COE agreed to amend the definition of ‘Salvage Packaging’ to include that salvage packagings may be used for "non-conforming" dangerous goods packages. The US-DOT supported this position.
STEEL DRUM INDUSTRY NEWS, TRENDS AND ISSUES
Archive for February, 2000
There has been great focus by the US to prevent imported wood products from China that often contain the destructive Asian Longhorn Beetle, from entering the country. The Asian Longhorn Beetle infestations have resulted in thousands of trees being incinerated in Chicago and New York City. In addition to the US, Canada, Japan, New Zealand and Australia have also established import restrictions on some wood products. Now with similar concerns, the Chinese government claims that shipments from the US and Japan containing solid wood packing, has been found to carry Pinewood Nematode causing Pine Wilt disease. Therefore, effective 01 January 2000, all coniferous solid wood packing material will have to be heat treated for a minimum of 30 minutes with a core temperature reaching at least 56 C (133 F). Shipments entering China will have to bear the newly required Certificate of Heat Treatment. Non-compliant shipments will be destroyed or returned to the site of origin. For additional information, visit the USDA-APHIL website at: www.aphis.usda.gov/travel/aqi.
Are you aware that shippers and companies importing products in non-bulk containers often find that their packaging is not compliant for the contents? And are you aware that the remediation costs for these non-complaint containers is usually borne by the consignee? When importing product, the containers arriving to the US, must be compliant with US-DOT regulations. A recent illustration of this problem came to light after approximately 200 steel drums arriving from China,were detained at a US port because there was no UN embossment on any part of the container. The only marking noted was a durable side label. A container that is made abroad does not void importers or shippers from the responsibility of complying with domestic US regulations.