Customer Testimonials

Oak Ridge National Laboratory / Lockheed Martin Energy Research

Mr. Paul Rankin
Reusable Industrial Packaging Association (RIPA)
6401 Corporate Drive
Landover, Maryland 20785

Dear Paul:

In reference to a recent telephone conversation that Howard Skolnik had with Bill Noell in our organization, the following information is furnished in regard to gathering information for DOT review, as applicable to Lockheed Martin's Oak Ridge, Tennessee facilities' position on the current DOT requirements for closing instructions for UN Hazardous Material Packagings.

The two Lockheed Martin facilities in Oak Ridge, Lockheed Martin Energy Research Corporation (LMER) and Lockheed Martin Energy Systems, Inc. (LMES), package large amounts of hazardous wastes and hazardous materials in drums. Lockheed Martin does not purchase the same size or type drum from the same supplier each time an order is placed. However, according to the DOT, instructions from each manufacturer for each drum must be used for filling and closing operations.

Due to the type of operations at LMES and LMER facilities, packages are not filled on a production line, as in a typical manufacturing operation, but in the field. Thus, insuring that a varied number of technical closing instructions for a variety of drums are available, understood, and complied with is a constant challenge. This problem is further complicated by the fact that manufacturers identify their drums in different ways; some use codes, some use initials, and some use their name. This makes it more difficult for operators and supervisors to determine the appropriate closing instruction for the drums being used.

In November 1998, Lockheed Martin Transportation and Packaging Management organization (LMTPM) submitted a letter to the DOT, Edward Mazola, in regard to an interpretation to 49CFR, 178.2(c)(1), citing the variations in closing instructions received from drum manufacturers for virtually indentical drums; such as 55 gallon, 16 gauge, UN 1A2 open head drums. LMTPM inquired whether the most restrictive of these furnished closing instructions could be utilized in the LMER/LMES plant system for all drums of a size and type, in lieu of distributing the various instructions. Although a written interpretation was not received, a DOT employee stated by telephone call that each individual manufacturer's closing instruction must be used or the manufacturer must agree to an alternate method.

LMTPM's hazardous material packaging specifications are on the web for both internal and external use. Hyperlinked into the packaging specifications are the packaging filling instructions which contain the manufacturers' closing instructions. These closing instructions are more complicated to maintain than are the detailed packaging specifications which, in LMTPM's opinion, are more vital to safe transportation in commerce than the various closing instruction for each manufacturer's package.

LMTPM is of the opinion that this detailed requirement of the DOT interpretation of the regulations is overburdening to industry and does not address a safety issue. For example, experience shows that torquing a locking ring to a specific torque setting (because that was the torque used when the package was tested) is not really the critical factor for safe transportation in commerce. The realistic measurement for an open head drum is that the locking ring is tight immediately prior to shipment. If the locking ring can be turned, indicating compression of the gasket or crush of the curl, the drum is not tight and will allow moisture in or fumes out during shipment regardless of what torque value was used in closing. The torque requirement for the bung closures on tight-head drums is more realistic; although the type of gasket used and compression after storage can offset the benefits of complying with a specific torque requirement.

LMTPM believes that standard wording could be established for the closing of drums and used by all drum manufacturers and other personnel in the packaging industry. It is therefore the opinion of the LMTPM that the DOT should encourage industry to adopt standard closing instructions with clear and concise verbiage in line with the recommendations stated in the SSCI manual,"Understanding POP for Steel Drums and Pails", under Section III, Package Selection, but eliminating the specific torque value requirements.

If RIPA has further questions on this subject, please contact W.C. Noell at 423/241-4489.

Yours very truly,

Sylvia D. McGhee
Packaging Operations Manager
Lockheed Martin Energy Research

SDM:cp

cc: Howard Skolnik