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Refilling / Reusing 45 Gal Drums


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Looking for some input to help me settle a discussion with a friend in the industry regarding the refilling & reuse of 45 Gal fuel drums in the field.

 

Is this an OK / accepted / common practice? We're talking about same-day use, not for fuel caches (obviously there'd be concerns about the seal for long term storage). I've worked with some operators who do it, and some who do not.

 

Thanks in advance!

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There are no limits for the number of times you can fill a tank that I know of. 45 gal drum is just that, a single wall tank which has damage limits, if kept in good shape what is the issue? Need a seal, buy the kit or use tamperproof tape. Had this arguement with a uppermanagement nitwit from another division years ago who emphatically told us to cease all refilling of drums no matter what logical explanations I provided. I eventually told him he needed to go thru the proper chain of command and would take my direction from my supervisor. He stomped off called our division's operations manager and was solved. Kept filling drums...was no logical, regulatory or safe reason to stop. Your customer may have policy otherwise which of course you will have to deal with. But pretty much all drums get refilled whether or not in your possesion or in fuel supplier's. Have it done carefully and responsibly then BFD. You cannot get your tanks or drums refilled by a shell fbo at an airport,,,,yet they refill thier own drums,,,,is it a liability issue not safety issue.

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Most of the esso drums we use factory filled with Jet-A come with a large sticker saying "this product in this container size not regulated by TDG" .

Jet B may different I wouldn't know never used it but regardless it's only for transport not how did the fuel get in to the drum

I have purchased new tamper proof seals when refilling drums but the issue is potential algae growth which comes down to tank maintenance once the spores are in your base tank it can spread and when pumped into a drum and sealed for months could be an issue

Some things to note

1 only use lined drums ( no bare steel)

2 check for water every time

3 don't use damaged drums ( the lining can be dislodged internally

4 never store upright

5 dispose of damaged or dirty drums right away

6 the person filling should be trained as to what to look for

7 repeated use can wear rubber seals and allow water in

 

There is a place to buy new lined drums in Vancouver with tamper seals I have purchased over 40 in the last 3 years

Use them till there skunky and toss them (they are not a long term solution)

I think the oil companies demonize this a little but short term the risks are manageable

DSL

 

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I shake-blocked ( and others) for years up and down the coast utilizing used drums.....correct refuelling gear, with standpipes the proper length, a good flashlight, a water test kit, and a good supply of filters and common sense ensures it a safe practice!

Oh yeah......be sure to ground properly!!!!!!

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There's no denying this can be done correctly, but....

 

http://www.tc.gc.ca/eng/tdg/clear-part5-300.htm#sec512

 

Classes 3, 4, 5, 6.1, 8 and 9 Dangerous Goods 5.12 Small Means of Containment

Beginning on January 1, 2003, all small means of containment used to contain dangerous goods included in Class 3, 4, 5, 6.1, 8 or 9 must be UN standardized means of containment. For small means of containment manufactured or marked in Canada, this is achieved by compliance with CGSB-43.146 or CGSB-43.150. These are the Canadian standards for UN means of containment for dangerous goods inClass 3, 4, 5. 6.1, 8 or 9. Non-UN means of containment, such as TC or DOT specification drums made before 2003, may be converted to the UN standards if they meet the requirements in CGSB-43.150.

(1) A person must not handle, offer for transport or transport dangerous goods included in Class 3, 4, 5, 6.1, 8 or 9 in a small means of containment unless it is a UN standardized means of containment selected and used in accordance with sections 2, 3, 12 and 13 of CGSB-43.146 or sections 2 and 3 of Part I of CGSB-43.150 and sections 12 to 17 of Part II of CGSB-43.150.
SOR/2011-60

(2) A person must not reuse a steel or plastic drum with a capacity greater than or equal to 150 L to handle, offer for transport or transport dangerous goods that are liquid and are included in Class 3, 4, 5, 6.1, 8 or 9 unless
SOR/2011-60

(a) for a steel drum, the requirements for the reconditioning, remanufacturing and repair in Part II of CGSB-43.126 are complied with and the drum reconditioning, remanufacturing and repair facility is registered with Transport Canada in accordance with the requirements of Appendix A of CGSB-43.126; or
SOR/2011-60

( b ) for a plastic drum, the requirements for the reconditioning, remanufacturing and repair in Part III of CGSB-43.126 are complied with and the drum reconditioning, remanufacturing and repair facility is registered with Transport Canada in accordance with the requirements of Appendix A of CGSB-43.126.
SOR/2011-60

These regs changed in 2011 ... would they not now preclude the re-use of 45 gal drums? In spite of the fact that we have been doing this for years AND it has been demonstrated that this practice can be executed safely?

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saturnman is hitting on my side of the argument. While I agree with all of you above, that if done properly there's no logical reason why we can't safely reuse drums, heck I've done it and seen it done in multiple companies myself... BUT, it would seem it's not kosher so far as TDG regs are concerned. I can't find any exemptions or provisions that allow us heli-industry end users to bypass those regs either. Are we all just operating in a grey area and hanging our a$$es out in the wind to get bit by the first inspector who happens to feel like enforcing that particular reg on that particular day? Not sure I feel comfortable hanging my hat on the "common sense / not logical / been doing it fine for years" argument.

 

Feels like one of those "Norms" from the Human Factors training courses to me. But then, how the heck is the average bush pilot supposed to operate efficiently??

 

Keep the discussion going, it's good to hear all sides!

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It's discussions like this which highlight the difference between regulating to cover your arse & common sense(not very common unfortunately)?

I have worked for a number of companies who refil drums & have never had an issue, but you need to be self disciplined with your standards relating to contamination control. My current employer refils drums from our tanker. Before filling the drums are inspected, cleaned(if required) , refilled, resealed with new seals(every time), sealed with the metal crimp-on seals & labelled with the fill date & batch number from the fuel supplier. A bit of mucking around, but it keeps our fuel integrity intact.

I've just used about 100 new drums supplied from a fuel distributor in the last month & EVERY single drum had traces of water in the bottom, so I'd argue that we actually get a better product when we fill them ourselves from our tanker! Our spears are the correct length so as to not pick up small amounts of water so it's not an issue, but it's still disappointing to pay big bucks for a shiny new drum & have water in it.

Unfortunately TC cannot control how operators carry out refilling operations, so I guess it's legally prudent to say you can't do it.

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