Refilling / Reusing 45 Gal Drums

[Skidz]

I spoke to a former TC dangerous goods inspector about this thread last weekend. He said he'd read it and perhaps put in his 2 bits. What Bif said is the correct interpretation, but TC knows that everybody does it (refill and transport used drums), and not only in aviation.

 

The logic behind it is that drums when inspected, filled, sealed and labelled by a properly equipped and authorized supplier are supposed to meet certain "crashworthiness" standards if you will. Refilled drums with not enough air will leak, too much air can be an explosion risk, rusty and/or banged-up drums can leak or crack of handled roughly, yada yada yada...

[Bif]

I spoke to a former TC dangerous goods inspector about this thread last weekend. He said he'd read it and perhaps put in his 2 bits. What Bif said is the correct interpretation, but TC knows that everybody does it (refill and transport used drums), and not only in aviation.

 

 

Did you get the impression it's something they let slide? Or would an inspector be likely to start writing up fines if they happened upon someone actively doing this.

 

Don't get me wrong, I'm not out crusading to have every operator who refills drums get fined and ticketed. I just wanted to find out the "official" rules for our own purposes.

[Skidz]

 

Did you get the impression it's something they let slide? Or would an inspector be likely to start writing up fines if they happened upon someone actively doing this.

 

Don't get me wrong, I'm not out crusading to have every operator who refills drums get fined and ticketed. I just wanted to find out the "official" rules for our own purposes.

 

We didn't really get into that. It was more of a rolling of the eyes and "yeah, I know everyone does it" kind of thing. I know he left TC because he was discouraged at the lack of resources to get "anything done" (his words verbatim). As with everything having to do with TC, I think the actions taken will probably vary greatly from region to region, and even from one POI to another.

[saturnman]

Want to resurrect this a bit:

 

Anyone out there using PLASTIC drums for drummed fuel? It seems there are some fuel caches down east with these drums. Personally, I've never seen or used plastic drums for Jet A. any special bonding issues? I know that these drums need to be certified per the TDG regs ...

 

Feedback is welcome.

 

S/M

[sirlandsalot]

I have heard several different times about static charge that builds up in Plastic, like using a jerry can. I think that is against sop's for many companies, even though steel drums re-used and used at caches are accepted.

 

never seen palstic 45's for fuel before, just water.

[skullcap]

Static does not build up in plastic anymore than steel,,,it just does not dissipate. Companies that allow use of plastic jerry cans have sops for ensuring there is a bonding wire fed in thru the vent hole to help with this issue. I would surmise that if you have a plastic standpipe for pumping fuel this will be a huge issue. However with a conductive standpipe such as aluminum or bronze(I hope no one is using steel anymore,,,duh spark) and your standpipe is bonded thru the fueling gear it is a safe as any. Far as the barrel,,,in other countries they use plastic drums for fuel. I think is more of a problem with who supplies them sealed.

[skullcap]

I guess if it does not dissipate then it probably builds up to higher charge so yes would infact build up more,,,sorry bout that.

[alphonso]

This refilling drums but not being allowed to use them unless they meet section 5.12- 2 (a) "reconditioned drums" is an issue that has come up and, like many it doesn't make sense to me, but the great thing about aviation is that there are rules to follow i.e. no grey, just black and white.

https://www.tc.gc.ca/eng/tdg/clear-part5-300.htm

 

5.12 Small Means of Containment

(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 that is selected and used in accordance with sections 2, 3 and 12 of CGSB-43.146 or a means of containment that is selected and used in accordance with sections 2 and 3 and Part 2 of TP14850.
SOR/2014-152

(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

 

So I poked around a bit and found this. I was wondering if this excludes the above rule and we can now pitch the refilled drums into the back of a pick up and haul them out to the job site with impunity (making sure they are clean, not leaking, secured etc).

 

https://www.tc.gc.ca/eng/tdg/clear-part1-475.htm

 

1.33 Class 3, Flammable Liquids: General Exemption

SOR/2008-34

Part 3 (Documentation), Part 4 (Dangerous Goods Safety Marks), Part 5 (Means of Containment), Part 6 (Training), Part 7 (Emergency Response Assistance Plan), Part 9 (Road) and Part 10 (Rail) do not apply to the handling, offering for transport or transporting of dangerous goods included in Class 3, Flammable Liquids, on a road vehicle, a railway vehicle or a ship on a domestic voyage if the dangerous goods

(a) have no subsidiary class;

b- are included in Packing Group III and have a flash point greater than 37.8°C; and

c) are in one or more small means of containment designed, constructed, filled, closed, secured and maintained so that under normal conditions of transport, including handling, there will be no accidental release of the dangerous goods that could endanger public safety.
SOR/2008-34

So from what I can tell Jet fuel has no subsidiary class (UN 1863), is in Packing Group III, has a flash point greater than 38°C and small containment means less than 450 litres water equivalent - much larger than a 205 litre drum.

Anybody out there any good at interpreting bureaucratese?

[__________]

HV,

 

Been to quite a few airports in the north, didn't now the fueler well but guess it's more common up there when there's no other options. Most don't mind filling empty drums they just make u fill them if there still in the back of the heli.

[alphonso]

Jet A applies to 1.33 and so drums can be refilled with it.

 

Jet B does not apply due to a Flash Point lower than 37.8 C.

 

Depending on your company's Dangerous Goods certificate (the way I see it), Jet B can be transported to limited access sites in refilled drums.

 

Jet B cannot be transported anywhere else unless in new or reconditioned drums.