Refilling / Reusing 45 Gal Drums

[Bif]

I guess the TDG issue is TRANSPORTNIG the drums once refilled.

 

For use at caches etc. it should be no problem to refill the drums and use as you see fit as long as the drums are clean and in good shape.

 

Cheers

H.

 

But how are the drums getting there, Winnie? Unless the fuel source is right there, in which case why are you filling drums? I can see your point being valid if your company has a refuelling truck that goes to road accessible caches and fill drums in situ, then technically you're not transporting them.

[Whitestone]

As perplexing as it is, if you are to follow the letter of the law, the only way to refill the 205 litre drums is if you are a designated inspection facility or (?) have had the drums inspected at one. It says HANDLE as well as offer for transport or transport so that is all encompassing. No storage, no long lining, etc.

 

I had my whole last seasons fuel supply deliverd in drums on pallets and when i got there they were still all sitting on the pallets! Of course with water on top of nearly every one ! Grrrr......

 

W.

[Harmonic_Vibe]

Many Operators rely on the CSA standard, which TC recommends and most fuel suppliers abide by, for refueling operations at aerodromes, which precludes refilling drums. That's why unless you know the guy really well they will never refill drums at an airport. But they will happily fill your rusty old Tidy Tank!

 

The Transportation of Dangerous Goods Regulations (the Canadian ones) allows drums to be refilled and transported under certain conditions:

 

http://www.tc.gc.ca/eng/tdg/clear-part12-466.htm#sec129

12.9 Limited Access General

(1) An air carrier may handle, offer for transport or transport by aircraft within Canada the dangerous goods referred to in subsections (2) to (12) if

(a) the air carrier complies with subsections (2) to (14);

( the air carrier complies with the following requirements in the ICAO Technical Instructions:

...

© the dangerous goods are

(i) transported by cargo aircraft or passenger carrying aircraft referred to in Subpart 4 of Part VI and Subparts 1 to 4 of Part VII of the “Canadian Aviation Regulations”,

(ii) transported to or from a location where access is limited and there is no other practical or readily available means of transport to transport the dangerous goods, and

...

Class 3, Flammable Liquids

(2) The requirements in subsections (3) to (6) apply to dangerous goods that are included in Class 3, Flammable Liquids, and that are

(f) UN1863, FUEL, AVIATION, TURBINE ENGINE, Packing Groups II and III only.

(3) When the Class 3, Flammable Liquids, referred to in subsection (2) are

(a) contained in a small means of containment that is a drum, the drum must be securely closed and marked with one of the following manufacturer's permanent markings when the drum has a capacity greater than 25 L and less than or equal to 230 L: TC, CTC, DOT, ICC 5A, 5B, 5C, 17C, 17E, TC-34, CTC-34, DOT-34, UN 1A1, UN 1B1, UN 1H1 or UN 6HA; or

[Translation]

Whether it is short term or long term storage of fuel, many customers' policies are against the practice of refilling. The original label may say do not re-fill. Our supplier filled only new drums and all returns were crushed for recycling.

 

The new drums are thin so dent and rust easily.

Of course you can't be care full enough to check quality

The rubber seal will crack easily especially with age so do not over tighten the bung.

After tipping over the drums, check for leaks before flying off.

 

 

Like everything else, the pilot has the last say. Some pilots simply refuse to use refilled drums, can you blame them? It only take one bad one to ruin your day. Most of my bad drums were from new sealed from the factory, however. Usually as a result of improper bung torque and incorrect storage by the dealer.

[vibe]

I am far from being an expert on drum refueling but here are some of my opinions on fuel handling and drums usage;

 

Your company should have a fuel handling manual that specifies how you will ensure that the fuel being used meets the type certificate requirements. Aviation fuel is tightly controlled during production and through the supply chain. Once delivered to the operator it is the operator’s responsibility to ensure that the standard of quality is maintained until dispensed into an aircraft.

 

The Canadian Standards Association B836-05 is a recognized standard for fuel handling at aerodromes. Reuse of aviation drums is not recommended in B836-05. Your company manual should then provide an equivalent level of safety by controlling the process of reusing drums. (This covers your butt.) This doesnt prohibit the reuse of drums but controls it so that safety is maintained to a consistent standard.

 

When reusing drums you must “know” the history of the drum, not just assume that it is clean and safe to use. For example a clean looking drum that has been laying around the job site may have been temporally used for other products that you wouldn’t want flowing through the FCU. Proper filtration can only do so much and no filtration system is perfect.

 

Sealed drums of jet from a dealer may have water in them due to temperature changes. There is always dissolved water in jet fuel. This is an inherent property of jet fuel. As the temperature of the jet fuel drops the fuel can change from clear to cloudy and if the temperature continues to drop the water can condense out of the fuel and drop to the bottom of the sealed drum as free water. (This can also occur in an aircraft tank either on the ground or at altitude.) Drummed fuel from any source has to be inspected prior to use.

 

As the end user of the fuel the pilot must be confident that the fuel in the aircraft is correct and safe. Reuse drums as required but be clear on who accepts the fuel and the liability.

 

John

[Bif]

http://www.tc.gc.ca/eng/tdg/clear-part12-466.htm#sec129

12.9 Limited Access General

(1) An air carrier may handle, offer for transport or transport by aircraft within Canada the dangerous goods referred to in subsections (2) to (12) if

(a) the air carrier complies with subsections (2) to (14);

( the air carrier complies with the following requirements in the ICAO Technical Instructions:

...

© the dangerous goods are

(i) transported by cargo aircraft or passenger carrying aircraft referred to in Subpart 4 of Part VI and Subparts 1 to 4 of Part VII of the “Canadian Aviation Regulations”,

(ii) transported to or from a location where access is limited and there is no other practical or readily available means of transport to transport the dangerous goods, and

...

Class 3, Flammable Liquids

(2) The requirements in subsections (3) to (6) apply to dangerous goods that are included in Class 3, Flammable Liquids, and that are

(f) UN1863, FUEL, AVIATION, TURBINE ENGINE, Packing Groups II and III only.

(3) When the Class 3, Flammable Liquids, referred to in subsection (2) are

(a) contained in a small means of containment that is a drum, the drum must be securely closed and marked with one of the following manufacturer's permanent markings when the drum has a capacity greater than 25 L and less than or equal to 230 L: TC, CTC, DOT, ICC 5A, 5B, 5C, 17C, 17E, TC-34, CTC-34, DOT-34, UN 1A1, UN 1B1, UN 1H1 or UN 6HA; or

 

 

It goes on to state:

 

"(4) The following means of containment may be reused to transport the Class 3, Flammable Liquids, referred to in subsection (2):

(a) a steel drum or jerrican, if

(i) neither the body nor the top or bottom of the drum or jerrican is damaged by wear, scoring, dents or corrosion to the extent that the integrity of the drum or the jerrican is compromised,

(ii) any worn or leaking bung caps or seals are replaced,

(iii) the top and bottom of the drum are not bulging, and

(iv) sufficient ullage is left to ensure that no leakage or permanent distortion will occur as a result of expansion of the liquid caused by any temperature that may be experienced during transport;"

Which to me, seems like a direct contradiction to the statements in Part 5 as mentioned by saturnman:

"(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"

I'm going to have to do some more digging, methinks!

[Winnie]

 

But how are the drums getting there, Winnie? Unless the fuel source is right there, in which case why are you filling drums? I can see your point being valid if your company has a refuelling truck that goes to road accessible caches and fill drums in situ, then technically you're not transporting them.

Yup I getcha!

 

That is what we ended up with last winter in Saskatchewan on a contract.

 

Drums where sent to a town on the Twin Otter, and came back refilled (at the end of contract, customer did not want to buy new ones I guess...) I did paste checks and visual inspection on every drum tho.

 

I guess we just have to follow the letter of the law better!

[Bif]

Sorry to dig up this thread, but I just thought you might want to know the results of my diggings. I spoke to several TDG reps in various provinces, and while a few of them gave me conflicting info, I feel like I get it now.

 

As HV stated above, Section 12.9 Limited Access supersedes Section 5.12.

 

So... we are allowed to refill and reuse empty fuel drums in the field, but ONLY for transport by air, ONLY under Limited Access provisions, and ONLY if the drums are in good condition, and space is left for expansion of the fuel (standard practice).

 

The real world application of the above means that while we are permitted to sling refilled 45 Gal drums of Jet Fuel, we CANNOT transport them by ground or by water.

[skullcap]

So question for your TDG reps, do they understand or perhaps do you understand the difference between reuse and refill. In the world of "re" ha, ha the definition of reuse is to change the contents from what the container is labelled to another so jet A to deisel. This is what I believe they are prohibiting inho. Refilling is selfdefining and truly think they do not have issue with. Why would the tdg folks have issue with the lack of a seal as long the contents are what the labeling/placards says?

[Bif]

Ehhhhh... I think you'd have a hard time finding a rep that would agree with your train of thought, Skully.

 

I think the regs are pretty clear, and maybe it's my fault for using reuse/refill interchangeably. But it's pretty clear they mean once a new & sealed drums has been opened and drained, you cannot refill it (with the labelled contents or otherwise) and then transport it (expect under the limited access provisions).

 

Keep in mind, this is only referring to transport. No one's saying it's illegal to refill a fuel drum, I'm sure you can do that to your heart's content, you just can't take 'em anywhere (unless you're flying them under limited access).