On September 1st, 2006 the DOT published HM-231, a Notice of Proposed Rulemaking (NPRM) focused on changes to packaging requirements. Of the items indicated, one of the proposals would allow for the permanent bottom UN marking of a steel drum to be different than the durable side marking. Only a few years ago, some manufacturers were applying side marks at lower test levels than the bottom marking. DOT insisted that the side and bottom markings had to be the same so they modified the CFR per the current 178.503(a)(10). HM-231 proposes to reverse this decision. Skolnik believes that the UN markings must be clearly understood by users and that, having two different marks on a single drum is very confusing and dangerous. Some manufacturers use one drum to satisfy many of their customer‘s requirements and having the same bottom and side mark requires that they change the bottom head production embossment for each order. In the case of the HM-231 proposal, a manufacturer could use the higher rated bottom head marking for a multitude of customer-required marks that are lower then the bottom marking. Confusing? If you agree, DOT is accepting responses to the NPRM.
DOT/UN