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

Can A UN Marked Liquids Drum Be Used For Solids?

October 5th, 2004 by Bill Fitzgerald

Filed under: DOT/UN, Safety

Our customers are frequently asking this question. While most of the open head drums manufactured by Skolnik are dual tested and marked for both liquids and solids, the closed head drums are only tested and marked for liquids. However, in some cases, a product can be a liquid when filled and solidify during transport. In this case, some inspectors have declared that as solids, they should be in a solids container. Thus the shipment is declared non-compliant and refused. In CFR 49 173.24a(b)(3), DOT does permit the use of a liquids container for a solid, and offers an equivalent calculation to achieve container maximum weight for single or composite packagings that are Packing Group I, II or III. If a shipper can comply with this calculation and indicate that the liquids container does comply with 173.24a(b)(3), then shipping the solid in the liquid marked container is compliant. Of course, the dual marked container is still preferable.

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2 Responses

  1. Jim Powell says:

    Hi Howard, any idea why IATA (seems to) not recognize this provision? DOT allows it, but a forwarder claims IATA told them they won’t permit it. This is a 1A1 drum filled with a liquid that solidifies during transport and later is headed up slightly to empty it. I was trying to find something in IATA that would permit it and instead found (2) that seems to prohibit it. Customer (a forwarder) indicates they talked with David Brennan and he said no, it wasn’t allowed. DOT explicitly (as you point out here) allows it.

  2. Jim,
    Good question. If a hazmat carrier understands that contents can change during transport due to temperature, I believe they tend to regulate for the more difficult state. Even though DOT/UN does allow for transport of a solids inside a closed head drums (173.24a(b)(3), they are most likely to consider this to be a liquid transport as the liquid poses the greatest risk to the transport. This is up to interpretation by the carrier, and in the case of IATA, it is likely that they view this allowable interpretation to be questionable. If you truly believe that this applies to your client, then you need to make the case with IATA via the designated carrier.
    Let me know if you find a solution. Thank you,

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