Question:

If I have a single 55 gallon drum that weighs over 882 lb is it considered a bulk Wait! Stop! That question contains a false premise. I can’t consider the next question until I explain a bulk packaging and the limits on the maximum net mass of a 55-gallon  drum. The next question will have to wait for another article.

Answer:

Thank you for contacting me. Please allow me to provide some clarification on the term “bulk packaging”.

• A bulk packaging is defined at 49 CFR 171.8 in the Hazardous Materials Regulations (HMR).
• It reads in part:

…a bulk packaging has: * * *

(1) A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;

(2) A maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or

(3) A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.

emphasis added.

Read: Bulk Packaging for HazMat Explained!

• You do not state whether the HazMat in the drum is a liquid or solid – I presume it is not a gas – but, regardless, the maximum capacity of a bulk packaging must be greater than 450 L (119 gallons) for both a liquid and a solid HazMat.
• It is interesting to note that a bulk packaging for a solid must have a maximum net mass of greater than 400 kg (882 lb) AND a maximum capacity greater than 450 L (119 gallons).
• You indicate it is a 55-gallon drum. Therefore, its maximum capacity is 208 L. This can’t be a bulk packaging.
• You also write it weighs more than 882 lb (400 kg). Since this is the gross mass (weight of packaging and HazMat), I will presume the net mass (weight of the HazMat only) is also greater than 400 kg (882 lb); regardless, this is not enough to meet the criteria of a bulk packaging. *It is – in fact – a violation of the packagings specification and will be addressed later*

In sum: What you describe is a non-bulk packaging because its maximum capacity is well below the threshold required for a bulk packaging.

Now, how about that 55-gallon drum weighing more than 882 pounds?

• A 55-gallon drum used for the transportation of a HazMat must be designed, manufactured, tested, & marked to meet a specification acceptable to USDOT/PHMSA.
• I presume the specification in use here, as in most transport of HazMat in non-bulk packagings and IBCs, is the United Nations Performance-Oriented Packaging Standards (aka: UN Standard). The requirements for this specification are found at 49 CFR 178, subpart L.
• These regulations specify limits on the maximum capacity of all drums made to the UN standard; they are:

A plywood drum?!?

• As you can see from the table, no drum of any composition made to the UN Standard may exceed a maximum net mass of 400 kg (882 lb).
• If you have a 55-gallon drum that exceeds a maximum net mass of 882 pounds, it is a violation of the HMR at 49 CFR 173.22(a)(2) for the shipper to offer it for transportation to the carrier.
• It is a violation of the HMR at 49 CFR 177.801 for the carrier to accept a consignment containing a 55-gallon drum that exceeds a maximum net mass of 882 pounds.

I hope this helps. Please contact me with any other questions.

Conclusion:

He didn’t contact me with any follow-up questions. However, read here for the article that answers the question he posed after this one.