Corporate General Specification RD-139.1

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1 Corporate General Specification Corp. Package Engineering St. Paul, MN Document Information Reference ID Issue Date 10/18/2006 Status Approved Description CGS 139 General Requirements for U.N. Certified New, Alternate ID CGS 139 Reconditioned, and Remanufactured Drums Superseding ID Superseded By Issue Category Other Author Jill Buss Reason for Issue Initial transfer to IPM. See page 2 for details of changes. Primary Contact William Gramer Page 1

2 Description: General Requirements for U.N. Certified New, Reconditioned, and Remanufactured Drums Specification No.: 139 Supersedes Issue: 12/09/2003 Owner: William Gramer Change Record: Added photos to SCOPE: Corporate General Specification 139 is distributed to 3M s steel drum suppliers, manufacturers, reconditioners, and 3M operations that purchase drums. It outlines basic construction and performance requirements for new and reconditioned drums purchased by 3M Company. Duplication Note: For optimum reproduction of this document, copies should be made from laser printer, as photostat may distort the images. 1.0 DEFINITIONS 1.1 Abbreviations: U.S. DOT U.S. Department of Transportation I.M.D.G. International Maritime Dangerous Goods Code N.M.F.C. National Motor Freight Classification U.N. United Nations CFR49 U.S. Department of Transportation Code of Federal Regulations TDG Canada Transport Dangerous Goods Regulations RID/ADR European Rail and Road Agreement NOMS Mexican Technical Standards Supplementing Land Transport Regulations 1.2 Competent Authority A national agency as described by U.N. recommendations for transport of dangerous goods responsible under its national law for the control or regulation of a particular aspect of the transportation of hazardous materials (i.e. TDG, U.S. DOT, RIDADR, etc.). 1.3 Dangerous Goods A material which has been determined by a competent authority to be capable of posing an unreasonable risk to health, safety and property when transported in commerce (i.e. hazardous material, regulated material). 1.4 Drum A cylindrical shipping container made of steel with either a non-removable (tight-head) or removable (open-head) head construction. Either type may have flanged openings for additional closure options. The liquid capacity may range from four liters (one gallon) to 450 liters (119 gallons). The container can be stored or shipped without additional outer packaging. 1.5 Durable Marks A required marking describing a U.N. Certification which cannot be removed except by the reconditioning process (i.e. label, stencil, ink jet). 1.6 Flange A mechanism inserted or formed into a drum top or cover which accepts a closure. Page 2

3 1.7 Lining For purposes of this document, a lining is considered to be an interior applied coating (i.e. sprayed on) or roller coated. An insert such as a plastic bag or formed receptacle is not to be considered a container lining. 1.8 Permanent Marks A required marking describing a U.N. Certification which is non-removable by the reconditioning process (i.e. embossing). 1.9 Reconditioned A used container, cleaned, inspected, and restored to its marked performance level and design in accordance with competent authority and 3M requirements Remanufactured A used container, cleaned, re-worked, and marked to a design differing from the original design type (i.e. changing the container from a tight-head to an open-head). Before marking, prototype(s) are design tested annually to ensure updated U.N. certification U.N. Certification Marks Marking which indicates that the container design is manufactured and tested to meet applicable competent authority standards U.N. Certified Container A package assembly design which has been tested by a competent authority, at an approved testing facility, to perform at a performance level depicted in the certification mark as required by 3M Package Engineering. 2.0 GENERAL INFORMATION 2.1 Conformance All steel drums shall conform to the requirements of the applicable competent authority and industry/association standards as appropriate, as well as the requirements of this specification and the 3M item specification. The container must be manufactured by only those manufacturers approved by local 3M authority (i.e. in the U.S.) and as listed in the Purchasing Operating Policies and Procedures Manual, Section 85.22, Drum Suppliers. 2.2 Item Specification An item specification will be issued for each drum. The item specification contains additional variable and specific information not contained in this specification and has precedence over information contained in this specification. 2.3 Dangerous Goods Steel drums and their service parts furnished for the packaging and transportation of dangerous goods must conform to the appropriate regulations. They shall be marked as required by the current regulations and the item specifications. 2.4 Finishing Interior When linings are required, inner surfaces of the container body and heads/cover shall be uniformly coated according to the 3M item specification and lining manufacturer s specification. The lining will be checked by 3M Company for proper thickness by using a digital dry film thickness gauge. Page 3

4 The lining of removable head drums will be checked at three (3) equally spaced measurements across the cover and bottom; and one measurement in each 1/3 area of the side. Any single thickness measurement less than the thickness specified in the item specification shall be cause for rejection. Number of drums checked per production run shall be determined by the manufacturer. Results shall be made available to 3M upon request. Lining must be properly cured. To check for proper cure, rub the lining (50 strokes) with a clean cloth saturated with methyl ethyl ketone (MEK) applying moderate pressure while rubbing. No transfer of the lining to the cloth indicates a properly cured lining. To check for proper lining coverage, the lining will be coated with a 10% solution of copper sulfate. A change in the color of the drum metal indicates that there is insufficient lining coverage Exterior The outer surfaces of the container body and heads shall be painted with lead-free paint to the specified color, per the item specification, with a thickness adequate to give complete and opaque coverage. To check for proper paint adhesion, drop a 9kg (20 pound) weight having a 25.4mm (1 ) radius hemispherical shaped steel striking surface from a height of 0.9m (3 ) onto the uncoated side of a panel. Chipping or flaking of the coating constitutes an unacceptable finish. This test is to be conducted by the drum supplier as a means of qualifying the paint used. In addition, finished surfaces exposed for 90 days to outdoor climatic conditions must not have more than 10% surface corrosion. 2.5 Preparation for Shipments All containers are to be shipped the best way to ensure arrival at the destination in good condition. This method will be the manufacturer s option unless otherwise specified on the individual 3M Purchase Order. 120 liter (30 gallon) and 220 liter (55 gallon) drums shall be loaded in the upright position and the last row of drums must be secured in transit. The truck or trailer used for transporting drums must match 3M unloading facilities. 3.0 REQUIREMENTS: NEW STEEL CONTAINERS 3.1 Construction Non-removable heads shall be seamed to the body using a commercial non-hardening type compound, excluding welded head drums. Side seams shall be welded. Rolling hoops and beads shall be expanded or rolled in the container body, unless otherwise specified. Flanges are to be formed or mechanically inserted and shall be equipped with a gasket or sealing compound as specified in the item specification. 3.2 Bottom Head Construction Bottom heads of drums with a rated capacity of 120 liters (30 Gal) or 220 liters (55 Gal) shall be constructed with or without a stamped pattern as specified below. Bottom drum head shall not extend below a line level with the bottom chime. Cross-sectional drawings below are some samples of acceptable embossments: No Pattern: One Concentric Ring Page 4

5 3.2.3 One Concentric Ring Three Concentric Rings 3.3 U.N. 1A2 Series Closure Ring Construction In addition to the requirements specified in the U.N. regulations, the bolted closure ring for removable head drums shall be constructed as follows: Hexagonal bolt head and hexagonal locking nut size shall be 24mm (15/16 ) across flats. Bolt length shall be 101.6mm (4.0 ) long with continuous threads over its entire length. The threads of the bolt shall be free of excessive amounts of paint. The locking nut shall be tightened against or near the threaded lug of the closure ring or the bolt head, whichever position was used to achieve the U.N. certification (see 3.4). 3.4 Marking Requirements Important: Before new drums may be marked as certified U.N. containers, the following must be verified: Design qualification tests must have been performed to the performance level depicted in the new mark. Test reports must be maintained at the plant location where the new mark is applied. Test reports must be readily accessible to any representative from 3M Package Engineering upon request New Drum Marking Requirements Nine basic items must appear on the certification mark, in the following order, on each new drum. These items may appear in a single line or in multiple lines: (a) U.N. symbol (or just the letters U.N. for embossed metal) Page 5

6 (b) Packaging I.D. code (e.g. 1A1 steel closed head; 1B2 aluminum open head) (c) Letter corresponding to tested performance level (X, Y, or Z) (d) Specific gravity (for liquids) or mass to which drum is tested (for solids) (e) Test pressure in kpa (for liquids) or the letter S (for solids) (f) Last two digits of the year in which the drum was manufactured (g) Letters USA, if made in America (h) Manufacturer or test agency symbol or address (i) Nominal thickness to 0.1mm (mandatory if intended for re-use) (j) (Optional) Rated capacity in liters. The certification marks must be positioned on each drum subject to the following drum type, capacity and weight limits: If the total mass of the drum is: Certification mark must be placed on: If permanently marked on bottom of drum: Over 30kgs Side or Top Durable mark on side or top also If not permanently marked on bottom of drum. Permanently mark on side or top 30kgs or less Side, Top, or Bottom N/A N/A 49cfr178.3(a)(5) Capacity Marking Items Additional Requirements If the total capacity of the drum is over 100 liters Basic marks (a)-(f) and (i) must be embossed on the bottom. (a)-(j) may all be present, if desired. If total mass is over 30kg and the total capacity is over 100 liters, then all basic certification marks must also be placed on the top or side. These marks must be identical to marks embossed on bottom [except item (i) is not required] and may be durable. Regardless of capacity or gross mass, if a certification mark appears on the removable head of a 1A2 drum, a duplicate mark must also appear on the side and/or bottom - in accordance with the capacity and mass of the drum. 49CFR (a)(10)m 49CFR (b) The height of the letters and numbers of the U.N. certification marks on containers with a capacity greater than 30L (7.9 gallons) must be at least 12mm (0.47 ). The height of the letters and numbers of the U.N. certification marks on containers with a capacity less than 30L (7.9 gallons) must be at least 6mm (0.2 ) U.N. Marking Illustrations on New Drums Drum Type: Non-Removable Head Drum Sample Permanent Marking - Non-Removable Head Drum on Bottom Head <--Marking Location Sample Durable Marking - Non-Removable Head Drum on Side of Drum <--Marking Location U.N. Marking Illustrations on New Drums Drum Type: Removable Head Drum for Liquids Page 6

7 Sample Permanent Marking - Removable Head Drum for Liquids on Bottom Head<--Marking Location (For embossed metal drums, the letters UN may be applied in place of the United Nations symbol. Letter height must be a minimum of 12mm [0.47 ] ) Sample Durable Marking - Removable Head Drum for Liquids on Side of Drum <---Marking Location U.N. Marking Illustrations on New Drums Drum Type: Removable Head Drum for Solids Sample Permanent Marking - Removable Head Drum for Solids on Bottom Head<---Marking Location Sample Durable Marking - Removable Head Drum for Solids on Rear Top<---Marking Location 4.0 QUALITY ASSURANCE PROCEDURES -- NEW DRUMS 4.1 Sample and Inspection Sampling and inspection of steel drums furnished to 3M Company will generally follow procedures described in Military Standard Mil-Std-105 (Sampling Procedures and Tables for Inspection by Attributes). The procedure used by 3M will be the Reduced Inspection, Double Sampling Plan, Inspection Level I, with an AQL 2.5 or locally approved plan. 4.2 Defects The following is a listing of defects for which steel drums or pails will be inspected. These defects are classified as SERIOUS, MAJOR, OR MINOR Serious Defects Page 7

8 Defects of this nature would normally result in rejection of the containers and be returned to the supplier. A. Improper Marking 1. For U.N. Certified Drums a. Marking lacking or incorrect 1. U.N. symbol (or just the letters U.N. for embossed metal) 2. Packaging I.D. code (e.g. 1A1 steel closed head; 1B2 aluminum open head) 3. Letter corresponding to tested performance level (X, Y, or Z) 4. Specific gravity (for liquids) or mass to which drum is tested (for solids) 5. Test pressure in kpa (for liquids) or the letter S (for solids) 6. Last two digits of the year in which the drum was manufactured 7. Letters USA, if made in America 8. Manufacturer or test agency symbol or address 9. Nominal thickness to 0.1mm (mandatory if intended for re-use) 10. Letter and/or numbers smaller than prescribed by the U.N. regulations 2. For Non-U.N. Certified Drums Meeting Industrial/Association Standards a. Marking lacking or incorrect 1. Manufacturer s name or symbol 2. Metal nominal thickness, drum capacity, year of manufacture B. Interior Finish 1. Lined Containers a. Incorrect lining b. No lining when one is specified c. Lined when not specified d. Improperly cured lining (See Section 4.1 of the Corporate General Specification) e. Improper lining application pin holes or absence of lining on any interior surface (See Section 4.1 of this Corporate General Specification) 2. Unlined Containers a. Excessive rust with obvious metal reduction C. Material 1. Type and thickness not as specified (i.e. use of.9mm when 1.1mm is required; or the use of carbon steel when stainless steel is required) D. Fabrication 1. Not in compliance with the item specification. E. Fittings 1. Not as specified F. Foreign Material in Drum 1. (i.e. dirt, heavy rust, metal particles, grease, and oil) G. Dents 1. On side or top larger than 12mm (1/2 ) in depth and/or 102mm (4 ) in diameter. 2. On bottom head (none acceptable) 3. On chime (none acceptable) H. Bottom Pattern 1. Bottom head stamped with a pattern not specified in Section 3.2 of this Corporate General Specification. I. Exterior Finish 1. Wrong color 2. Excessive scratches 3. Insufficient coverage Major Defects Defects of this nature would normally result in either rejection or re-work of the containers at the supplier s expense. A. Fittings 1. Missing components (i.e. nuts, bolts, gaskets, plugs, closing rings, or covers) Page 8

9 2. Closing ring construction not according to Section 3.3 of this Corporate General Specification. B. Openings (Closures) 1. In wrong location 2. Wrong size 3. Too many or too few C. Dents 1. On side or top less than 12mm (1/2 ) and/or 102mm (4 ) in diameter. D. Water in drums (to the extent that it exceeds damp areas or minor sweating) E. 3M I.D. number 1. Missing 2. In wrong location F. Closure ring 1. Not properly constructed according to Section 3.3 of this Corporate General Specification 2. Less than minimum clearance between nut or bolt head and ring or drum sidewall (see 3.3) Minor Defects Defects of this nature would normally result in use of the containers with supplier notification as to the defective items noted. A. Exterior finish 1. Surface rust 2. Peeling or flaking of paint 3. Color variation (shade difference) 4. Excessive runs or puddling of paint B. Small dents in side or top C. Interior finish 1. Light rust on interior of unlined container 5.0 REQUIREMENTS: RECONDITIONED OR REMANUFACTURED CONTAINERS 5.1 Reconstruction The containers are to be returned to their original shape, cleaned, repaired, refinished, and marked according to the following, and must be in such condition (including closure devices) that the containers comply in all respects with the prescribed requirements of the appropriate regulations for the containers ordered. Any drum meeting one specification, which has been altered to meet another specification, must be capable of meeting the new specification in all respects and marked accordingly as prescribed by the competent authority Preparation All removable parts (bungs, rings, bolts, and gaskets) are to be removed prior to reconditioning Cleaning The interior must be cleaned to bare metal and free of all contaminants. The exterior must be cleaned completely free from loose rust, scale, paint, or other contaminating material which would interfere with a firm bond between the metal and the exterior finish. All old markings including name of contents, addresses and labels must be completely removed before applying the external finish. 5.2 Marking Requirements Reconditioned Drum Marking Requirements If the following items (A) through (E) from a new drum certification mark no longer appear on the drum after reconditioning, the five items must be re-applied in a durable form in one of two ways: (1) The mark should depict the same performance as it did before reconditioning. (2) A new certification mark depicting a lesser performance level must be applied. (a) U.N. symbol (or just the letters U.N. for embossed metal) Page 9

10 (b) Packaging I.D. code (A1 steel closed head; 1B2 aluminum pen head) (c) Letter corresponding to tested performance level (X,Y, or Z) (d) Specific gravity (for liquids) or mass to which drum is tested (for solids) (e) Test pressure in kpa (for liquids) or the letter S (for solids) The following items must also be durably marked on each reconditioned drum near the five items described above: (f) USA (or country in which reconditioning occurred) (g) Reconditioner symbol (or address if not registered with DOT) (h) Year of reconditioning, last two digits (i) The letter R (j) The letter L, if successfully leak tested Embossing Original Manufacture Certification The drum reconditioner must ensure that the bottom head of the drum remains legibly embossed with the required marking, as specified by the competent authority. If the prescribed markings are not legible, the reconditioner must assume the responsibility of a manufacturer and emboss the side of the drum accordingly. The reconditioner is responsible for verifying that the metal thickness qualifies the drum as reconditionable Embossing Subsequent Design Original Embossing Containers originally manufactured and embossed for one design may be certified to another design Bottom Head Construction Acceptable Head Construction Bottom head constructions indicated in Section 3.2 of this Corporate General Specification are the only acceptable head constructions Unacceptable Head Construction Any other types, styles or forms of bottom head construction are not acceptable. Any re-working or re-shaping of the bottom head construction, except for re-shaping of the chime, is not acceptable. Noncompliance with the requirements of this section will be cause for rejection. Shown below are some examples of unacceptable bottom head constructions. Unacceptable Pie-Pan Bottom Head: Page 10

11 Qualifying for Re-use Metal drums used as single packagings are authorized for re-use only when the thickness in millimeters is permanently (embossed) marked on the drum and conforms to the following minimum thickness criteria: 20 liter ( 5 gallon) maximum capacity 0.63mm 120 liter (30 gallon) maximum capacity 0.92mm 220 liter (55 gallon) maximum capacity 0.92mm* *Minimum thickness of 0.82mm body thickness and 1.09mm head thickness are authorized if drum manufactured before January 1, Drums made on/after January 1, 1997 must have 0.82mm body thickness; 1.11mm head thickness The letters and numbers making up the drum certification marks must be 12mm (0.47 ) high; except for containers less than 30L (3.9 gallons) which must be 6.0mm (.2 ) high. See the following marking illustrations Marking Illustrations for Reconditioned Drums Reconditioned Non-Removable Head Drums Sample Durable Marking - Non-Removable Head on Side of Drum <--- Marking Location Reconditioned Removable Head Drums Sample Durable Marking - Removable Head for Liquid Drum on Side of Drum <--- Marking Location Page 11

12 5.2.3 Remanufactured Drum Marking Requirements If the remanufactured drum does not change in design, the following markings may be applied durably to the top head or side of the drum Remanufactured drums which bear a new design (i.e. open head created from a previously closed head drum, or a drum with a lesser nominal thickness) must be remarked in a permanent manner on the top head or side with the following required markings: (a) U.N. symbol (or just the letters UN for embossed metal). (b) Packaging I.D. code (e.g. 1A1 steel closed head; 1B2 aluminum open head). (c) Letter corresponding to tested performance level (X, Y, or Z). (d) Specific gravity (for liquids) or mass to which drum is tested (for solids). (e) Test pressure in kpa (for liquids) or the letter S (for solids). (f) Last two digits of the year in which the drum was manufactured. (g) Letters USA if made in America. (h) Manufacturer or test agency symbol or address. (i) Nominal thickness to 0.1mm (mandatory if intended for reuse). (j) (Optional) Rated capacity in liters. Items (a) through (f) and (i) must be marked permanently, while the remaining items may be durable. Location and size of markings must be in accordance with charts in Important: Before drums may be remarked as remanufactured containers, the following must be verified: Design qualification tests must have been performed to the performance level depicted in the new mark. Test reports must be maintained at the plan location where the new mark is applied Test reports must be readily accessible to any representative from 3M Package Engineering upon request Marking Illustrations for Remanufactured Drums When a drum remanufacturer/reconditioner changes the design or specification of a drum (i.e. convert non-removable head to removable), the remanufacturer /reconditioner must permanently mark the first line" information as illustrated. The original permanent (embossed) mark on the bottom of a non-removable head drum such as: must be changed to the following permanent mark on the side of the drum: Page 12

13 with additional durable marks on side of drum: USA / XXX Country of Origin Reconditioner s ID 6.0 TESTING 6.1 The entire surface of each non-removable head drum or each removable head drum (except for its removable head and adjacent chime area) must be tested for leakage by constant internal air pressure as shown on Table 1. The leakage test must be conducted by complete submersion in water for a period of time of at least 12 seconds. The air pressure indicated in Table 1 must be maintained for the period of submersion. The use of another method of testing must be approved in writing from the competent authority. Table 1 Air Test Internal Gauge Pressure Requirements Drum Pkg Group Minimum Test Pressure P.S.I.G.* X (I)** 30kPa (4.0 psi) Y (II) 20kPa (3.0 psi) X (III) 20kPa (3.0 psi) * If an air leak is detected, the drum does not qualify for reuse. ** Pkg Group I corresponds to X-marked drum, etc. Pkg Group II corresponds to Y-marked drum, etc. 7.0 QUALITY ASSURANCE PROCEDURES: RECONDITIONED OR REMANUFACTURED DRUMS 7.1 Sampling and Inspection Sampling and inspection of steel drums and pails furnished to 3M Company will generally follow procedures described in Military Standard MIL-STD-105. (Sampling Procedures and Tables for Inspection by Attributes) The procedure used by 3M will be the Reduced Inspection, Double Sampling Plan, Inspection Level I, with an AQL 2.5 or locally approved plan. 7.2 Defects The following is a listing of defects for which steel drums will be inspected. These defects are classified as SERIOUS, MAJOR, or MINOR Serious Defects Defects of this nature would normally result in rejection of the containers and returned to the supplier. A. Improper Marking 1. For U.N. Certified Drums A. Embossing lacking or incorrect 1. U.N. symbol (or just the letters U.N. for embossed metal) 2. Packaging I.D. code (e.g. 1A1 steel closed head; 1B2 aluminum open head) 3. Letter corresponding to tested performance level (X, Y, or Z) 4. Specific gravity (for liquids) or mass to which drum is tested (for solids) 5. Test pressure in kpa (for liquids) or the letter S (for solids) Page 13

14 6. USA (or country in which reconditioning occurred) 7. Reconditioner symbol (or address if not registered with DOT) 8. Year of reconditioning, last two digits 9. The letter R. 10. The letter L, if successfully leak tested. 11. Letters smaller than 12mm (0.47 ) on drums with capacity greater than 30L (7.9 gallons) and no smaller than 6mm (0.2 ) on drums with a capacity less than or equal to 30L (7.9 gallons). Example of UNACCEPTABLE drum construction marking: Note: Certification markings DO NOT include markings to show compliance with UN/DOT requirements. B. Interior Finish 1. Lined Containers a. Incorrect lining b. No lining when one is specified c. Lined when not specified d. Improperly cured lining (See Section of the Corporate General Specification) e. Improper lining application pin holes or absence of lining on any interior surface 2. Unlined Containers a. Excessive rust with obvious metal reduction C. Exterior Finish 1. Wrong color 2. Excessive scratches 3. Insufficient coverage D. Material 1. Type and thickness not as specified. E. Fabrication 1. Not in compliance with the item specification. F. Fittings 1. Not as specified 2. Closing ring construction not according to Section 3.3 of this Corporate General Specification. 3. All fittings must be tightened so as to seal the drum against leakage. G. Foreign Material in Drum 1. i.e. dirt, loose rust, metal particles, grease, and oil H. Dents 1. On drum side or top larger than 1/2 (12mm) in depth and/or 4 (102mm) in diameter. Page 14

15 2. On drum bottom head larger than 1/4 (6.35mm) in depth and 1 (25.4mm) in diameter. 3. On top or bottom chime area greater than 1/4 (6.35mm) from original radius line. Example of UNACCEPTABLE side dents: Example of UNACCEPTABLE bottom head dents: Page 15

16 Examples of UNACCEPTABLE bottom head dents: Page 16

17 Example of UNACCEPTABLE bottom head dent: Example of UNACCEPTABLE chime dent: Page 17

18 I. Creases and wrinkles 1. On drum side and top larger than 1/4 (6.35mm) from surface by 2 (50.8mm) long 2. On drum bottom larger than.125 (3.2mm) from surface by 1 (25.4mm) long Example of UNACCEPTABLE bottom head creases and wrinkles Example of UNACCEPTABLE bottom head creases and wrinkles Page 18

19 Example of UNACCEPTABLE bottom head creases and wrinkles: Page 19

20 J. Corrosion and pitting of metal 1. On drum bottom, side and top Example of UNACCEPTABLE corrosion and pitting of metal: K. Chime Damage 1. Dented chime area 2. Chime area rolled too think chime height not to exceed (15.5mm) (measured on outside of bottom) and chime thickness not to be less than (4.0mm). See sketch below. Example of UNACCEPTABLE chime height and thickness. Page 20

21 L. 220 liter (55 gallon) containers only the minimum height for open head containers shall be not less than 33 1/4 (850.9mm) with the cover and closure ring removed. M. Improper or no seal on drum flanges 1. All Tri-Sure flanges that have been incinerated must be fitted with a sealing collar or metal "Tab-Seal (Tri-Sure). The Tri-Sure sealing system is the ONLY approved method of sealing. N. Fittings on side of drum Reconditioned drums with fittings (flanges and plugs) of any kind or size in the side wall ARE NOT ACCEPTABLE. O. Bottom-head construction 1. Bottom-head construction MUST conform to the approved head constructions specified in Section 3.2 of the Corporate General Specification. a. Any other types, styles or forms of bottom head construction; or reworking or reshaping of bottom Major Defects Page 21

22 Defects of this nature would normally result in either rejection or rework of the containers at the supplier s expense. A. Fittings 1. Missing components (i.e. nuts, bolts, gaskets, plugs, closing rings, or covers). 2. Closing ring construction not according to Section 3.3 of this Corporate General Specification. B. Exterior Finish 1. Wrong color (i.e. blue rather than brown; not necessarily shade variations) C. Openings (bungs and flanges) 1. In wrong location no side fittings are allowed 2. Wrong size 3. Too many or too few 4. Unapproved bung/flange design/manufacture D. Dents 1. On side and top smaller than 1/2 (12.7mm) in depth and 4 (102mm) in diameter or smaller. 2. On drum bottom smaller than 1/4 (6.35mm) in depth and 1 (25.4mm) in diameter. 3. On top or bottom chime area smaller than 1/4 (6.35mm) from regular radius line. E. Water in drums (to the extent that it exceeds damp areas or minor sweating) F. 3M I.D. number 1. Missing 2. In wrong location Minor Defects Defects of this nature would normally result in use of the containers with supplier notification as to the defective items noted. A. Exterior finish 1. Excessive Surface rust 2. Peeling or flaking of paint 3. Color variation (shade difference) 4. Excessive runs or puddling of paint B. Small dents in side or top C. Interior finish 1. Light rust on interior of unlined container ** End of Document ** Page 22