Question1:

If I have a single 55 gallon drum that weighs over 882 is it considered a bulk… Hold it right there!

Answer1:

In an earlier article I addressed the false premise contained in that first question and explained that the packaging described (55-gallon drum) is not a bulk packaging and is violation of the HMR if it has a maximum net mass of more than 882 lbs; I suggest you read that article first (Q&A: Is a 55-gallon drum that weighs more than 882 pounds a bulk packaging?). In this article I’ll answer the remaining questions poased as if it is a bulk packaging (it isn’t).

Question2:

“…and would it require a un number…”?

Answer2:

“…and would it require a un number”?

• Yes. The HazMat’s identification number must be marked on both a bulk and non-bulk packaging.
• There are several options for the display of the identification number on a bulk packaging:
  • A bulk packaging with a capacity of 3,785 L (1,000 gal) or more must display the identification number on all four sides.
  • A bulk packaging with a capacity of less than 3,785 L (1,000 gal) may display the identificatin number on only two opposing sides.
  • There are several options for the display of hazard communication on an intermediate bulk container (IBC).

Question3:

“next question if I have a bulk container that requires a un number but I also have non bulk waste under the same un number do I have to placard my trailer with both the un number and a class placard or will the un number cover both.”?

Answer3:

• Both the placard and identification number must be displayed on the vehicle.
• If the identification number displayed on a bulk packaging is not visible in transportation, e.g., it is inside a cargo trailer, then it is necessary to display the identification number on all four sides of the vehicle.
• A bulk packaging containing any amount of any HazMat requires the vehicle to display the applicable placard for the HazMat on all four sides of the vehicle.
• In this case the vehicle must display the identification number and the applicable placard for the HazMat in the bulk packaging. This can be displayed in one of three ways:
  • The identification number may be displayed on the placard.
  • The identification number may be displayed near the placard on an orange panel.
  • The identification number may be displayed near the placard on a white square-on-point.

• If an identification number is displayed on a vehicle it must represent all of the HazMat of that Class in the vehicle. Since you indicate you have a bulk and non-bulk packaging of the same identification number, a placard representing the Class and the identification number must be displayed on all four sides of the vehicle. Read: When not to Display and ID# on a Vehicle

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

Conclusion:

A tough question because the inquisitor started with an incorrect understanding that its OK for a 55-gallon drum to weigh more than 882 lb – it’s not!

Sometimes knowing the right question to ask requires a basic understanding of the USDOT/PHMSA Hazardous Materials Regulations. My monthly HazMat Employee Training Webinars can do just that.

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.

June 11, 2020:

Daniel

I have read your Bulk Packaging for hazmat.  I have a questions regarding the aerosol cans packed in an 11G fiber cubic yd boxes (aka: an intermediate bulk container or IBC). You have confirmed placards and UN numbers are not required due to inner containers. If boxes do display placards 2.1 with the 1950 across in the white panel would this be a violation for over placarding?

Thanks for your help.

My reply the same day:

Thank you for contacting me. I will try to answer your questions. Please see below.

• I presume you are referring to the following Q&A at the end of the article:

Q: Are aerosol cans loaded in a UN specification bulk packaging, i.e. an 11G fiberboard Intermediate Bulk Container (IBC) subject to the marking, labeling and placarding requirements for a bulk packaging?

A: No. The definition of a bulk packaging specifies that it must contain hazardous materials that are loaded with no intermediate form of containment. The aerosol cans in the 11G box would be a form of intermediate containment and, thus, not considered a bulk packaging. It is interesting that in this situation what may start as a bulk packaging may not continue to meet the definition depending on how it is used.

• As a rule, using hazard communication in excess of what is required, as long as the HazMat is present and other conditions are met, is not a violation.
• I will need more information about your situation: Are the aerosols in this case being transported as a waste for disposal or recycling?

Please advise.

Some more information on June 11, 2020:

Thanks Daniel for helping me.

I did call the DOT hotline and since the cubic yard box is acting as on overpack for the aerosol cans the placard with the UN number across the middle would not apply. I looked at Large Packaging requirements which do contain inner containers but the 11G IBC does not meet the requirements of a Large packaging since it does not exceed 119 gallons.

We are shipping these for disposal (hazardous waste).

We normally have the yellow haz waste marking with all the generator information, shipping description etc and a 2.1 placard with 1950 across the middle on two opposite sides of the IBC. Would this still be acceptable by DOT or a violation?

Thanks so much for your help.

Still June 11th, my reply:

I will do my best to answer your question and provide guidance. Please see below.

• I believe the Q&A in my article on bulk packaging & your call to DOT confirms the cubic yard box with aerosols is not a bulk packaging. Therefore, it could display the labels and marks as if it is a non-bulk packaging.
• Non-bulk packagings must be display labels in compliance with 49 CFR 172, subpart E.
• A placard with the ID # displayed on it will not meet the specifications of a label. I believe it would be a violation to display the placard instead of the required label.
• However, it is not a violation to use hazard communication in excess of what is required as long as the hazard is present. You could display the placard in addition to the label, but not in place of it.
• There is a good exception from full regulation for aerosols shipped for disposal or recycling at 49 CFR 173.306(k). Using it makes discussion of labels and placards on the cubic yard box unnecessary.

Also…

It didn’t come up in this Q&A, but check to see if your state has adopted the USEPA’s Final Rule including aerosol cans as a universal waste.

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

And, the next day, her final reply:

Thanks for your help. I start confusing myself when reading and rereading the requirements.

Conclusion:

There’s no shame in admitting you may become confused by the regulations (it happens to me all the time). The solution is to sit down and carefully review the regulations, guidance documents, and interpretation letters of the respective agency until you can finally make sense of it all. Or call me.

A question received February 01, 2018:

Hello Daniel,

I am contacting you with a question on the bulk/non-bulk classification. I work for a company that ships explosives in fiberboard drums. These drums hold no more then 100lbs but they are shipped in a tractor trailer unit that can hold up to 42,000 lbs. I am not sure if this is a bulk packaging with the fiberboard drums being an intermediate container or if it is considered non-bulk packaging because the only amount that is considered is the amount put in one fiberboard drum.

Any help on this matter would be great!

Best Regards,

My reply February 12, 2018:

Thank you for contacting me. Please see below.

• The packaging you describe (fiberboard drums of no more than 100 lbs) are a non-bulk packaging. They do not meet the definition of a bulk packaging. Read: Bulk Packaging for HazMat Explained!
• The tractor trailer unit is the transport vehicle – more specifically: the motor vehicle since it is used for transportation by highway – for the HazMat packagings. It is not a bulk packaging.
• The only type of bulk packaging that contains an intermediate form of packaging is the large packaging which is not what you describe.

I hope this helps. Please don’t hesitate to contact me with any questions. I have provided training and consulting services for others in the ordnance/explosives industry in the past.

Just a quick question June 19, 2018:

Is carrying 40 – 55 gallon drum of NaOH on a box trailer considered bulk?

Sent from my iPhone

My reply just an hour later:

No it is not.

Please see below for an explanation:

• A bulk packaging is one with a capacity of greater than 119 gallons. Read: Bulk Packaging for HazMat Explained!
• Your containers are 55 gallons each.
• The total volume of the shipment is not a factor.
• You may, however, need to display the identification number for the hazardous material on the vehicle.
  • Read:  Vehicle Marking Requirements for Large Quantities of a Single Hazardous Materials in Non-Bulk Packagings
  • Read: Display of the Identification Number on Transport Vehicles and Freight Containers

Her gracious reply:

Thank you. That’s what I thought but just wanted to make sure.

I wasn’t done (I have so much to share!):

You’re welcome!

You may wish to read this article I wrote indicating when it is necessary to display the identification number on a transport vehicle if it contains a large quantity of a single HazMat:  Vehicle Marking Requirements for Single HazMat.

That spurred another question (06.20.18):

I read the other article you sent and it did clear up when to use numbered placards on a straight forward shipment. Other scenarios would also be helpful.

• What if you picked up a shipment carrying 11,000 lbs each of two different chemicals from one shipper? Total 22,000 lbs?
• Same scenario but you picked them up from two separate shippers?
• Another:  Picked up 11,000 lbs of one chemical and 4,000 lbs of another chemical? One shipper and then two shippers?

My reply the next day:

I will attempt to answer your questions below.