Mitchell Container Services, Inc.

Intermediate Bulk Containers (IBCs), 55 Gallon Drums Steel and Plastic
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Compliance Regulations

Steel Drums: Minimum Thickness for Reuse and Reconditioning
The use and reuse of packaging’s such as steel, 55-gallon drums for shipping hazardous materials is strictly regulated by the U.S. Department of Transportation’s Hazardous Materials Regulations (HMRs)

Under the regulations at 49 CFR 173.28(b)(4), a metal drum is authorized for reuse, with or without reconditioning, when its actual thickness is no less that 0.92 mm and the drum is permanently marked (e.g., embossed) with the nominal thickness of the steel as described at 49 CFR 178.503 (a)(9). Factoring in the standard +/- variance for steel thickness in a sheet, the nominal mark embossed on the bottom of a drum meeting the minimum of 0.92 mm throughout would be “1.0”. (The unit of measure, in this case mm, is not needed in the embossment).

A special provision also authorizes steel drums for reuse if their actual thicknesses are no less that 0.82 mm in the body and 1.11 mm in the heads. Drums embossed with the mark 1.1/0.8/1.1 may meet these minimums after factoring in the +/- variance on the “plus” side and confirming that the minimums are indeed met. However, drums embossed with a nominal mark of 1.2/0.9/1.2 will in all cases meet these minimums.

U.S. regulations do not allow the reuse of steel drums with an embossed mark of less than either “1.0” or “1.2/0.8/1.2”, although drums marked “1.1/0.8/1.1” may meet with the minimum thicknesses for reuse if actual thicknesses can be confirmed by some means.

Posted: 1/4/2010

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