Ask the Expert, Hazardous and Solid Waste, Q&A

Reusing Drums for Transport

Q. Can we reuse drums with UN rating code Y1.5/100 to transport two hazardous wastes with the DOT UN numbers of UN1263 and NA3077?

A. You have asked whether you can reuse a drum with UN rating code Y1.5/100 (that you received holding a shipment of “painting products”) to transport two hazardous wastes with the DOT proper shipping names and UN numbers of UN1263, “Waste paint related material, 3, P. G. III ERG 128” and “NA3077, Hazardous Waste, Solid, NOS (Chromium, Selenium), 9, P. G. III 171”.

We assume from your question that the UN1263 material and the NA3077 material would each be in their own drum with a UN rating of Y1.5/100, and would not be combined in the same drum.

A drum with a UN rating of Y1.5/100 could be used for each of these two materials provided several conditions are met to comply with both the requirements for hazmat transport and the requirements for management of hazardous waste. Those conditions are as follows:

Concerning the hazmat requirements, both your hazardous wastes are in Packing Group III, and the drum’s UN rating code of “Y” (indicating the packing group) is suitable for both Packing Groups II and III. The drum’s UN rating code of “1.5” is the designation of maximum rated specific gravity (i.e. how much weight can be put in the package (the drum)). The contents of the drum must therefore not exceed 1.5. The “100” that follows the specific gravity in the UN rating code to indicate the hydrostatic test pressure, in this instance, that the drum is rated to withstand a maximum of 100 kilopascals (kPa) of pressure (which is relevant especially if transport is to be by air).

The hazardous waste container requirements require that the container made of or lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored (40 CFR 264/256.172). When you gave us the UN rating code, you did not include the first part of the code (the packaging identification code), so we do not know the nature of the material of the drum (e.g. plastic, steel, etc.) which must be considered in determining whether the hazard classes of your two hazardous materials (Class 3 and Class 9) are compatible with the drum. In addition, hazardous waste must not be placed in an unwashed container that previously held an incompatible waste or material (40 CFR 264/256.177).


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