Skolnik

but are they losing the war? Usage of steel drums continues to defy contenders as being the most reliable packaging for the shipment of dangerous goods. However, while the popularity is sustained, there are many manufacturers who are reducing metal thickness in order to postpone price increases. The result is that while these thin gauge steel drums are able to qualify for the minimal requirements of the DOT and UN certification, they do not perform as well in-field. Gone are the days of drum failures due to seam leaks — today’s most common incidents are related to fork-lift puncture and material handling. This change in the type of incidents, and the reduction of metal thickness leads one to conclude that these thin walled drums might be paving the way for a new set of in-transit incidents. Furthermore, shippers of steel drums fail to realize the g-forces associated with steel drum shipments and often ignore or underestimate adequate blocking and bracing preparation. CFR49 173.28(4)(i) states that for steel drums intended for reuse, 0.92mm is the minimum allowable steel gauge or a 0.82 body is allowed if the heads are 1.11mm. Even at these minimum levels, we recommend that thicker options are justified by the reduced risk of the transport package. Let’s win the battle…and the war, by reducing in-transit incident risks, not the steel.

UN packagings are fabricated and tested to specific levels of performance. These tests allow a manufacturer to mark the packaging with the appropriate testing criteria (ie: packing group, maximum gross weight, contents). Often, users innocently alter the integrity of the package by adding accessories (ie: a plastic liner) or by replacing accessories with different components (ie: closure ring, gasket) in which case, the certification of the package can be voided if not re-tested for qualification. “A different packaging” is defined in CFR49 178.601(c)(4) as a packaging that differs from a previously produced packaging in structural design, size, material of construction, wall thickness or manner of construction. Further design qualification testing is not required if the alterations to the packaging do not constitute “a different packaging.” Also, Closure Instructions are packaging specific and must be used only for the packagings as designated.