Stainless Steel Drums
Pipeline and Hazardous Materials Safety Administration · Feb 4, 1993 · Reference No. 93-0293
Interprets: 49 CFR § 178.83-2, 49 CFR § 178.83-11, 49 CFR § 178.83-13, 49 CFR § 178.83-14
Reggie’s quick take
A company asked whether about 300 stainless steel drums made between 1940 and 1970, which carry no specification marking, could be certified to DOT Specification 5C. PHMSA said converting them counts as new manufacture, so each drum must meet all DOT-5C requirements, including the capacity rule in § 178.83-2 and the leakage and other tests in §§ 178.83-13 and 178.83-14. Each drum must also carry the proper specification marking under § 178.83-11. The agency also warned that after October 1, 1994, drums could no longer be made or certified to DOT 5C, and that DOT specification packagings could not be used for shipping hazardous materials after October 1, 1996.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your December 14 letter to Ms. Susan Murphy, requesting guidance on the certification of stainless steel drums to DOT Specification 5C. You stated in your letter that you have approximately 300 stainless steel drums manufactured between 1940 and 1970 which you would like to certify to DOT Specification 5C. The drums currently are not marked to any specification.
The conversion of a non-specification drum to a specification drum is considered new manufacture within the context of the Hazardous Materials Regulations. Each drum must meet all requirements of the DOT-5C, for example the rated capacity prescribed in 49 CFR 178.83-2, and the tests prescribed in 49 CFR 178.83-13 and 178.83-14. These tests include a leakage test on each drum. Test samples must be retained in accordance with 49 CFR 178.13-13(a).
Drums must be marked with the appropriate specification identification in conformance with 49 CFR 178.83-11. The specification marking may be embossed on the drum head, die stamped or embossed on footrings on drums equipped with footrings, or it may be placed on a metal plate securely attached to the drum by brazing or welding in conformance with 49 CFR 178.83-11(a).
Be advised that after October 1, 1994, drums may no longer be manufactured and/or certified to DOT Specification 5C. After that date, drums must be certified to the United Nations performance standards adopted under Docket HM-181 (See 49 CFR Part 178, in the edition revised as of December 31, 1991). The standard for a non-removable head steel drum is the UN 1A1. After October 1, 1996 , DOT specification packagings may no longer be used fro the shipment of hazardous materials. You may wish to consider certifying these drums to the UN 1A1 standard in addition to or in lieu of DOT Specification 5C.
We trust we have answered your inquiry.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.