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Industrial Packaging for Critical Contents

Drum It Up! Steel Drum Industry News, Trends, and Issues

Archive for 2005

UN Packagings And Design Qualification Re-testing

November 8th, 2005 by Howard Skolnik

Filed under: DOT/UN

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.

Take A Holiday From Our Obsession With Thin

November 8th, 2005 by Howard Skolnik

Filed under: Safety

With Thanksgiving only 2 weeks away, I know that this is one day when I won’t have to suffer the consequence of thinness. Faced with product issues relating to thinning steel and thinning plastic – we spend our year looking for options that will slenderize our “thickness”. Diets promote the benefits of living a thinner life but, like drums, too thin can cause bodily harm. Steel drums of thinner steel yield material handling issues that effect our public safety and thin walled plastic litre bottles of soda forever fall out of my hands causing a cola mess! “ THIN – THIN – THIN – ENOUGH!!” For this Thanksgiving, I hope that all our Newsletter readers will take a vacation from “thin” and enjoy a hearty meal with family and friends. Let your waistband thicken for just a few days and celebrate the bounty of America. Happy Thanksgiving!

Salvage Drum CFR Definition Modified

October 4th, 2005 by Howard Skolnik

Filed under: DOT/UN, Industry News, Salvage Drum

Last month, the Final Rule for HM-189Y included a number of editorial and error corrections. Included in these was the addition of two semi-colons and a word correction in 49CFR 173.3 (c) Addressing Salvage Drums. The insertions further refine the distinct circumstances that permit the use of Salvage Drums. The modified text defines the use of Salvage Drums as: “Packages of hazardous materials that are damaged, defective, or leaking; packages found to be not conforming to the requirements of this subchapter after having been placed in transportation; 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 under the following conditions:…” Correction was needed to clarify that salvage drums could be used prior to, during and post transportation. This revision was effective September 28th, 2005.

PHSMA States Position On Closure Instructions For Returnables

October 4th, 2005 by Howard Skolnik

Filed under: DOT/UN, Industry News

In accordance with 49CFR 178.2(c), closure instructions are required to be supplied by manufacturers and distributors of all UN certified packagings. Responding to an inquiry from a filler who owns their IBC fleet, PHSMA applied the applicability of 178.2(c), for the return of empty, used, Intermediate Bulk Containers (IBC‘s). In their response, PHMSA stated that yes, per 178.2(c)(1), each person to whom a packaging is transferred must be notified of all requirements not met at the time of transfer and must receive written closure instructions. It is the responsibility of the manufacturer or other person certifying compliance with Part 178, and each subsequent distributor of the packaging, to provide the notification. The applicability of this interpretation to a third party sale of the IBC was not addressed. PHMSA’s response was a bit unclear, but they appear to be suggesting that it is good practice for all persons transferring IBC‘s (and other UN packagings) to a third-party, to include closure instructions.