Salvage Drum Requirements

This is in response to your letter requesting a clarification on the use of a salvage drum under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a salvage drum marked "UN 1A2/X445/S" may be used as a single package for hazardous material solids.

Yes, a salvage drum marked "UN 1A2/X445/S" may be used as a single packaging for a hazardous material solid when it is prescribed or permitted in the non-bulk packaging section specified in column (8B) of the § 172.101 Hazardous Materials Table (HMT) for the material being packaged. As with any UN standard packaging, the packaging must be compatible with the lading (e.g., corrosivity, permeability) and, the performance level for which the packaging has been tested (e.g., packing group, gross mass) may not be exceeded. See §§ 173.24 and 173.24a.

To avoid confusion, the word "SALVAGE" marked on the drum may be removed or covered when offered for transportation under these circumstances. If a UN standard drum is to be reused, it must conform to the reuse conditions specified in § 173.28 prior to being refilled.