plastic packaging

Q&A: Can I reuse plastic HazMat packagings for off-site transport of hazardous waste?

Q&A: Can I reuse plastic HazMat packagings for off-site transport of hazardous waste?

Question (January 09, 2021):

Good morning,

We are reusing plastic drums to send waste back out. The max net mass is 400 kg. Does that mean we cannot fill the drums over 400 kg each drum, even if palletized for transport?

Drum of corrosive hazardous waste



Thank you,

Answer (January 18, 2021):

Thank you for contacting me. I apologize for my delay. There are several issues brought up by your question that I will address in addition to answering your question. Please see below.

Note: all of the following is based on the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).

  • First of all, it is acceptable under the HMR for a HazMat packaging that previously contained a hazardous material to be used for the off-site transportation of a hazardous waste if done subject to the exception at 49 CFR 173.12(c). Read: Reuse of HazMat Packaging for the Shipment of Hazardous Waste
  • Secondly, under the international regulations of the International Air Transport Association (IATA) and the International Maritime Organization (IMO) a plastic drum, jerrican, or intermediate bulk container (IBC) is limited in its use to no more than five (5) years from its date of manufacture. However, no such limit applies to transportation by highway or rail solely within the U.S. For clarification of this point, read the two following letters of interpretation from USDOT/PHMSA (the HMR lacks a clear statement on this subject but it most certainly does not limit the lifespan of a non-bulk packaging):
    • From LOI 99-0246: “Non-bulk specification packagings do not ‘expire'”.
    • And, from LOI 97-0002: “A shipper may purchase a UN packaging, store it indefinitely and then use it without any testing requirements”.
  • Packagings are limited by their type to a maximum net mass and maximum capacity. No non-bulk packaging may exceed a maximum capacity of 450 L (119 gal) or 400 kg (882 lb). Pursuant to §178.509(b)(7 & 8), a plastic drum can not exceed the following limits:
    • Maximum capacity of 450 L (119 gal).
    • Maximum net mass of 400 kg (882 lb).
  • So, to be clear: the plastic drums can not be filled with a hazardous material to a net mass of more than 400 kg (882 lb). The palletizing of the drums after being filled does not effect the per packaging limit of 400 kg (882 lb).

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

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

That did it!

Reusing a HazMat packaging for the off-site transportation of hazardous waste is a compliant way to save money – no sense buying new drums to ship out hazardous waste! However, in addition to the conditions of the exception, the remaining requirements of the HMR remain for the packaging. That includes complying with its capacity and net mass limits.

 

Q&A: Is my plastic packaging OK for HazMat transport after five years?

Q&A: Is my plastic packaging OK for HazMat transport after five years?

A question 02.23.21:

Good morning,

I am the supervisor of the transportation of my organization. We are a small operation and have 2 plastic 5 gallon pails (1H2), that we utilize only for ground transport on our own vehicle (own driver) to move small quantities of samples from our lab to another off-site lab (about 3 miles away). We use these very infrequently if sample size exceeds excepted quantity amounts.

The pails were manufactured in 2011 and I have the UN Certification testing documentation and closure instructions.

My question is whether this packaging is now considered expired? And if not expired, am I required to have updated UN testing documentation (as it has been renewed) for these pails?

I saw a response you had published on an article on-line regarding plastic pails (relevant text is below) and you referred to these two letters of interpretation. I found LOI 99-0246 on-line, but have not found LOI 97-0002. Do you have a copy of LOI 97-0002 for my files?

“Though a clear citation in the HMR is lacking, the following letters of interpretation clarify the DOT’s position on limits on the term of use for a packaging:

· “Non-bulk specification packagings do not ‘expire’” [LOI 99-0246]

· “A shipper may purchase a UN packaging, store it indefinitely and then use it without any testing requirements” [LOI 97-0002]”

Thanks for your help,

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
My reply the next day (02.24.21):

Thank you for contacting me. Please see below.

  • Short answer: No. The Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the USDOT (USDOT/PHMSA) do not have an expiration date for an unused UN standard packaging.
  • However, the international regulations of the International Air Transport Association (IATA) and the International Maritime Organization (IMO) limit the use of a plastic drum or jerrican as a single packaging to five (5) years from the month and year marked on the packaging.
  • Also, the HMR limits the reuse of a plastic packaging to no more than five (5) years if it is intended to contain free liquids and it has not been leakproofness tested.

Read: The Reuse of Hazardous Materials Packaging

  • I believe the activity you describe (transporting small amounts of HazMat by highway as a private carrier) is eligible for the Materials of Trade exception.
  • Under this exception a UN standard packaging is not required and this entire correspondence is moot.
  • Links as old as 97-0002 (from 1997!) are only available through USDOT/PHMSA’s oCFR Tool. However, I have downloaded it and have it available here: LOI 97-0002.

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

I hope this helps. Please contact me if you have any other questions.

Conclusion:

That did it! The expiration date for certain plastic packagings is one of the significant differences between domestic regulations in the U.S. and the international regulations. Make sure you have identified the regulations applicable to your HazMat transportation and know what is required for compliance.