Question: Is it legal and appropriate to ship flammable liquids in a plastic 55-gallon drum? What should you do if a product is both flammable and corrosive and therefore would corrode a steel drum?
Answer: It may be legal and appropriate to ship a flammable corrosive liquid in a plastic drum. But, it’s impossible to make a blanket statement that applies to all flammable corrosive liquids.
Every facility that generates hazardous wastes that will be shipped offsite needs to be aware of both the RCRA and DOT regulations that apply to shipping hazardous materials. One of the first steps is to participate in DOT Hazmat Shipper Training that will teach you how to choose the right container and correctly mark and label it for shipment. The training usually takes three days, and you’ll want to come prepared to learn.
One of the things you will learn is how to read the 49 CFR 172.101 Table that lists hazardous materials by their proper shipping name and provides you with the information you’ll need to choose an acceptable container and mark and label it properly for shipment. You’ll also learn how to fill out a manifest and other things that anyone shipping hazardous wastes and signing manifests needs to know.
The DOT Table can seem a bit overwhelming with all of its columns and sub-columns, but it does contain the information you need to choose your container and, with training, it is much easier to comprehend.
For example, columns 7 to 10 list restrictions that apply. Sometimes, there are volume restrictions. Other times, the material may be prohibited from being transported by a specific type of transportation, such as air. Any restrictions on container type or size will also be listed.
The catch is that the columns listing the restrictions don’t come right out and say, for example, “You cannot use a steel drum.” The columns contain reference codes that must be looked up to determine what the prohibitions are. Again, training helps you translate and decipher these codes so you can be sure you’ve chosen the right container for your liquid.
Believe me, nearly everyone who has gone through choosing a proper shipping name and the correct container wishes that there was an easier way. But with so many different types of hazardous materials, shipping containers and modes of transport, shipping is complicated. Taking the time to do it right is not only a legal obligation — it helps prevent serious incidents while materials are in transit.