When I was a boy, my parents bought a new TV. My mom saved the box for the TV and she said “If we ever need to return this thing, this box is the only box it will fit in.” My mom doesn’t work around hazardous materials, but she understands that reusing packaging can be an economical and efficient practice.
So what about packages that once contained hazmat? How do we know when DOT will allow us to reuse a package, e.g., a drum? What are the requirements for reusing packaging, and where can shippers find them?
Get certified to ship hazmat with any major highway carrier! Lion’s two-day Hazmat Ground Shipper Certification (DOT) workshop comes to Cleveland, Pittsburgh, St. Louis, and Chicago before the end of 2018. US DOT requires training for all "hazmat employees" who can affect the safety of hazardous materials in transportation.
General Requirements for Hazmat Packaging Reuse
The regulations for reuse of packagings that once contained hazardous materials are located at 49 CFR 173.28. They contain requirements for the general reuse, more specific requirements for packagings such as drums, and exceptions from the rules for the shipment of hazardous waste.
Basically, packaging that is going to be reused must be able to meet the same requirements as if it were new
, including all outer, inner, and intermediate packagings. Packaging needs to be strong enough to handle conditions encountered during transport, such as mishandling and rough roads.
To be reused, packaging must be inspected before each reuse, must be free of incompatible hazardous material residue, and must not have any loss of structural integrity. That means you can’t use a fiberboard box with a tear or a drum with deep gouge on the surface. Metal and plastic drums and jerricans must also meet minimum requirements for wall thickness, and in most cases, they must be leakproof tested.
How to Assess a Box for Reuse to Ship Hazmat
If a hazmat shipper wants to reuse a box, they must ensure that the packaging can still meet all design and testing requirements as prescribed in 49 CFR 178.512 to 178.517 and 178.601.
The shipper must determine if the packaging is structurally sound for reuse. And unless the shipment is excepted, such as limited quantity shipments, the shipper must follow the manufacturer instructions for assembly and closure.
Additionally, the shipper must determine if the packaging is authorized for the hazardous material; meets all general requirements, such as compatibility; and also follow any special provisions that are listed for the material. [49 CFR 173.22]
How to Re-test and Reuse Drums and Jerricans
Reusing metal and plastic drums requires the shipper to follow some extra requirements. If the drum is going to be reused to ship liquids, it must be leakproof tested. The test must be performed as described in 49 CFR 178.604, using air or other suitable gas. The drums must be tested to the following pressure without leaking:
- Packing Group I: Equal to or greater than 48 kPa (7.0 psig)
- Packing Group II: Equal to or greater than 20 kPa (3.0 psig)
- Packing Group III: Equal to or greater than 20 kPa (3.0 psig)
Once the packaging has successfully passed the test, the letter “L”, the name and address of the person performing the test, and the last two digits of the year the test was performed must be marked on the package. If the person/company has a manufacturer symbol that has been approved by DOT, it may be used in place of the name and address of the tester.
L Bob Clarke 555 Garden St. Sparta NJ 18
L VL824 18
Metal and plastic drums and jerricans must also meet minimum wall thickness standards and must be marked to indicate as such, according to 49 CFR 173.28(b)(4).
Reusing Packagings for RCRA Hazardous Waste
Packagings, such as drums, may be reused for shipments of hazardous waste without a leakproof test being performed if all the following requirements are followed:
- All packagings must be authorized, must meet general requirements, and are subject to any special provisions as required by 49 CFR 173.22.
- All shipments can be transported by highway only.
- All packagings must be closed and not offered for transport until at least 24 hours after closure. Immediately prior to shipment, packagings must be inspected to ensure it is free of leaks.
- Packages must be loaded by the shipper and unloaded by the consignee, unless a private or contract carrier is used.
- Packagings can be used only once under these provisions to ship a hazardous material.
Hazmat Packages You May NOT Reuse
Reuse of packagings constructed of paper, except fiberboard, plastic film, and textiles, is forbidden per 49 CFR 173.28(b)(3). These types of packagings are more likely to contain incompatible hazardous materials and tend to break down over time quicker than packagings that are constructed of more durable materials, such as steel or aluminum.
Why Reuse a Hazmat Package?
Reuse of packagings can be an economical and environmentally sound management practice, but care must be taken to make sure that they are able to make it through the rigors of transport and comply with all required regulations listed in 49 CFR.
Last Hazmat Workshops of 2018!
Get your hazmat training in before the year ends with the final DOT, IATA, and IMDG certification workshops of 2018. Join us in Pittsburgh on December 3—6 or Chicago on December 10—13 for comprehensive training to manage hazardous materials/dangerous goods shipping compliance by ground, air, or vessel.
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