Definitions of Salvage Packaging and Overpacks
Salvage packaging — special packaging for the transport, recovery or disposal of damaged, defective, leaking or nonconforming hazardous materials packages, or hazardous materials that have spilled or leaked [49 CFR 171.8].
- Salvage packaging includes both salvage drums and salvage cylinders, both of which are identified and explained at 49 CFR 173.3
- Salvage packaging is intended solely for the use of hazmat packages that are shipped for the purpose of recovery or disposal and are:
- Damaged, defective or leaking
- Non-conforming (i.e. not in compliance with the HMR)
- Hazmat that has spilled or leaked
Overpack — an enclosure used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages. An overpack does not include a transport vehicle, freight container or aircraft unit load device [49 CFR 171.8].
Overpack examples include one or more packages:
- Placed or stacked onto a load board such as a pallet and secured by strapping, shrink wrapping, stretch wrapping or other suitable means
- Placed in a protective outer packaging such as a box or crate
Additional Explanation of Salvage Drums
I will leave the explanation of a salvage cylinder to another article and devote the rest of this one to the salvage packaging known as a salvage drum as identified at 49 CFR 173.3(c).
A salvage drum may be used solely under one of the following conditions:
- Packages of hazmat that are damaged, defective or leaking before or after they’re placed into transportation
- Packages of hazmat found to be out-of-compliance with the HMR once in transportation and in possession of the carrier
- Hazardous materials that have spilled or leaked at any point during transportation
Most importantly, a salvage drum may only be used if one of the above conditions is true and the hazmat packaging is to be shipped for repackaging or disposal. A salvage drum may not be used when the hazmat will be shipped to its original intended destination.
Additional Explanation of Overpacks
The definition of an overpack at 49 CFR 171.8 (see above) is referred to at §173.25(a) where the overpack is further identified and explained.
The purpose of an overpack is to:
- Provide protection or convenience in handling of a package
- Consolidate one or more packages
An overpack is merely an enclosure used by the shipper (consignor) for the sake of convenience or better handling in transport. The definition is broad, so the DOT provides some examples of overpacks:
- Packages stacked on a pallet and secured in place by strapping, shrink wrapping, stretch wrapping or some other suitable means
- Packages placed in a protective outer packaging such as a box or crate
The DOT also excludes the following from being considered as overpacks:
- Transport vehicle, like a truck
- Freight container, like a roll-off box
- Aircraft unit load device
Requirements for Use of Salvage Drum
Shippers must meet the following requirements [49 CFR 173.3(c)] when using a salvage drum:
- Metal or plastic container
- Capacity of 119 gallons or less (a non-bulk packaging)
- Removable head
- DOT specification packaging with applicable UN Standard marking
- Sufficient cushioning and absorbent
- Visible markings:
- Proper shipping name
- Name and address of destination
- “SALVAGE” in letters 12 mm (0.5 in) high
- Required hazmat labels displayed prominently
Requirements for Use of Overpack
Shippers must meet the following requirements [49 CFR 173.25(a)] when using an overpack:
- Packaging in overpack must be authorized for the hazardous material by the regulations
- Overpack must not create a forbidden packaging (e.g. include two incompatible materials) and must meet the general requirements for packagings and packages
- Overpack must either be marked with proper shipping name and identification number and display the applicable hazmat labels for all packages it contains or markings must be visible through overpack
- Package orientation arrows (if required) must be displayed on two sides of the overpack regardless if they are visible through the overpack
- “OVERPACK” in letters at least 12 mm (0.5 in) high either must appear on the overpack if it contains DOT specification packagings or be visible through the overpack
If you are ever in a situation where you are required to use a salvage drum or if you wish to use an overpack, make certain you are using the correct terms and — most importantly — complying with the applicable regulations.
ricardo nazariosays:05/28/2019 at 9:36 pm
So, is the salvage drum different from salvage cylinder?
Isabella Andersensays:07/10/2019 at 2:40 pm
Hi there. Yes, salvage drums are designed to contain leaking or damaged drums so that they can be safely transported. Salvage cylinders are usually brought onsite to manage leaking or damaged compressed gas cylinders that cannot be transported safely. Hope this helps!
mark kearneysays:01/12/2020 at 12:20 pm
Can salvage drums manufactured with a UN rating bearing the letter “S” (e.g. UN1A2/X440/S) be used for drums, damaged or non-conforming, that contain liquid because the drum is considered an inner packaging?
Isabella Andersensays:01/30/2020 at 10:38 am
Hi there, when salvage drums are tested to receive their UN Rating, the testing criteria account for the fact that whatever is inside the inner container may be leaking. When a salvage drum is used to ship a damaged or non-conforming container, it must have an absorbent, cushioning material between the container and salvage drum to cushion the inner container and help absorb any free liquids [49 CFR 173.3(c)(2)]. Because of this, any liquids that escape a damaged inner container would be absorbed, negating the need for a liquids rating.
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