Drum manufacturers are required by the DOT to permanently emboss the bottom head of each drum with a "birth certificate" including the UN certification level, metal thickness and test approval. A durable marking (ink, stencil or label) is then required for similar information (except the metal thickness) on the side of the drum. In some instances, drum manufacturers have chosen to permanently emboss the highest test level on the bottom head and durably mark, by customer request, a lower test level for the durable mark. Some manufacturers argue that this allows them to use one drum for several test levels and they have asked that the head embossment and durable mark must indicate the same testing level and different markings on a single drum are not authorized.
DOT/UN
How long can a manufacturer use the leftover components from the previous year? For example, if a manufacturer has left over drum bottoms from 2009, but the drum is built in February or March of the following year, is this parctice acceptable? Is this a rule in 49CFR and where would I find it?
The regulation states that the marking on the bottom head must indicate the year of manufacture. In my opinion, if, as you stated, the bottom component is made in 2009 but is not seamed to the drum body until 2010, this does not comply with the regulation. Because this is a very difficult requirement, at Skolnik, we are careful about end of the year component inventories and discard unused heads at December 31. You can reference the regulation at:
http://edocket.access.gpo.gov/cfr_2009/octqtr/pdf/49cfr178.503.pdf
Scroll down to 178.503(a)(6).