Closure Instructions for steel drums require that the ‘art’ of closing a steel drum be translated into technical instruction. These instructions are written without any DOT guidelines, but must indicate the measures necessary in order to properly secure a package for transport. The DOT does expect Closure Instructions to include a reference to torque capacities. Be sure that each of your Steel Drum (and all UN packaging) suppliers are providing Closure Instructions that meet the requirements of CFR 178.2(c. Be sure to have the calibrated tools, on hand, necessary to comply with these instructions. You can reference the Closure Instructions for all Skolnik products.
DOT/UN
Hi Howard,
Trust all is well and business good! Because of Skolnik news, you seem to have a grip on lawyer jargin. I have a question to ask to see if can help clarify.
If a manufacturer of new drums or used drums, sends an open head drum to a filler that has the cover and ring on the drum but not sealed (held on for shipping purposes only) is there any responsibility of the manufacturer or reconditioner? Or is he responsible only to send closing instructions along with shipment? in other words, drum do not have to be sealed per closing instructions? Your thoughts.
Thanks,
Lenny
Hi Lenny,
All is well, and wet, in Chicago!
You pose an interesting question with a fairly direct answer. An empty packaging does not require UN certification.
Empty drums being transported are not subject to their UN mark. Once the hazardous contents are put into the drum, and the drum enters transportation, the closure of the drum becomes subject to completion of the manufacturer’s closing instruction and it’s UN marking.
Hope this is understood. Write back if you have another question. Also, I will add this to our blog!
Cheers!
Howard