9.4 Overpacking Nonbulk and Radioactive Packages
Key Takeaways
- NFPA 470 (2022) JPR 11.4.3.3 is overpacking nonbulk and radioactive materials: place a leaking nonbulk container into a larger open-head salvage drum with the leak oriented at the top when possible, add compatible absorbents, close the ring, and mark and label.
- 49 CFR 173.3(c) salvage drums are metal or plastic removable-head UN 1A2, 1B2, 1N2, or 1H2 packagings tested to Packing Group III or higher with a 20 kPa (3 psig) leakproofness test, capacity not over 119 gallons (450 L), marked SALVAGE in letters at least 12 mm (0.5 in).
- Fire-service overpacking of a leaker is DOT salvage packaging; a 49 CFR 173.25 overpack is a different enclosure usually used around undamaged specification packages — salvage drums are exempt from 173.25 under 173.3(c)(6).
- For leaking radioactive Type A or Type B packages, overpack using trained procedures and radiation survey; do not destroy required markings or package integrity more than needed, and maintain labeling on the recovery package.
- An 85-gallon open-head salvage drum is the usual recovery container for a 55-gallon drum; it is not a substitute for the original specification packaging of an undamaged shipment.
9.4 Overpacking Nonbulk and Radioactive Packages
Quick Answer: NFPA 470 (2022) 11.4.3.3 is overpacking nonbulk and radioactive materials. For a leaking nonbulk container, place it in a larger open-head salvage drum, leak at the top when you can, with compatible absorbents, then lid and closing ring, marks, and labels. 49 CFR 173.3(c) is the Pipeline and Hazardous Materials Safety Administration (PHMSA) salvage-drum rule: UN 1A2 / 1B2 / 1N2 / 1H2, Packing Group III or higher, 20 kPa (3 psig) leakproofness, capacity not over 119 gallons (450 L), marked SALVAGE in letters at least 12 mm (0.5 in). Radioactive Type A / Type B packages: overpack with trained procedures and a radiation survey; maintain labeling; do not destroy required markings or integrity more than needed.
Fire-service instructors say overpack the drum. DOT lawyers say salvage packaging. Both pictures are a leaking package going into a larger recovery drum. The written exam will use overpack because that is the JPR title. Shipping after the incident will use 173.3(c). Learn both so a stem that says SALVAGE does not feel like a different skill.
Salvage drum versus 173.25 overpack — do not mash the citations
A 49 CFR 173.25 overpack is an enclosure a consignor uses to protect, handle, or consolidate one or more packages. The inner packages are typically undamaged specification packages. If required marks are not visible, the overpack is marked OVERPACK in letters at least 12 mm (0.5 in) — including when a Class 7 Type A, Type B(U), Type B(M), or industrial package is required and those package-type marks are hidden.
A 49 CFR 173.3(c) salvage drum is for packages that are damaged, defective, or leaking, non-conforming packages already in transportation, and spilled material being shipped for repackaging or disposal. 173.3(c)(6) says the 173.25 overpack requirements do not apply to those salvage drums. You mark SALVAGE, not as a substitute for the proper shipping name, but in addition to the proper shipping name, consignee name and address, and labels prescribed for the material (173.3(c)(3)–(4)).
| Legal object | Typical inner package | Mark you are tested on | Capacity / spec floor | When technicians use it |
|---|---|---|---|---|
| Salvage drum 173.3(c) | Leaking or damaged nonbulk package | SALVAGE (≥ 12 mm) plus PSN, consignee, labels | ≤ 119 gal (450 L); UN 1A2, 1B2, 1N2, or 1H2; PG III or higher; leakproofness 20 kPa (3 psig) | CDP/TEEX drum over-packing; recovery of a 55-gal leaker |
| Overpack 173.25 | Usually intact specification packages | OVERPACK (≥ 12 mm) if inner spec marks are not visible | Not the 173.3 salvage test battery | Consolidation or protection of undamaged boxes; also the word NFPA uses for the skill |
| Salvage cylinder 173.3(d) | Damaged/leaking cylinder (with listed exceptions) | SALVAGE; ASME construction rules; no pressure-relief device on the salvage cylinder | Water capacity ≤ 119 gal | Not a 55-gal open-head drum skill |
Nonbulk (49 CFR 171.8) is the inner-package size limit from Chapter 4: liquid receptacle 119 gallons or less, and the matching solid/gas thresholds. A 55-gallon drum is nonbulk. A 275-gallon tote is bulk and is not this open-head 85-gallon trick. 85-gallon and 95-gallon open-head salvage drums are the usual recovery size for a 55-gallon drum; they still sit under the 119-gallon salvage-drum cap. A salvage drum is a recovery container, not a magic upgrade that turns a wrecked inner package back into its original UN specification for routine shipment as if nothing leaked.
Large salvage packagings in 173.3(f) exist for bigger recoveries (not by air) and are marked SALVAGE too. Do not invent their test numbers on the technician written; know they are not the 55-gallon skill drum.
CDP / field sequence for a leaking 55-gallon drum
Treat this as offensive containment into a recovery container, with confinement still running on the floor:
- Identify and PPE. Same sequence as 9.3. A salvage drum does not authorize Level D.
- Pre-stage the salvage drum: open-head steel or plastic that is compatible with the lading (173.3(c) opening sentence). Inspect the gasket and bolt ring. Place compatible cushioning and absorbent in the bottom so the damaged package cannot punch through and so free liquid is gone when the drum is closed (173.3(c)(2)).
- Orient the leaker: rotate so the leak is at the top when the drum’s remaining product and integrity allow it. A sidewall hole at the bottom dumps the rest of the lading into your gloves. A bung leak on a tight-head drum may already be on top — do not invert a liquid drum just to feel busy.
- Place the package. Do not drop it. Add more compatible absorbent around the sides so it cannot rattle.
- Lid, closing ring, tighten in the pattern the ring wants. A cocked bolt ring leaks later on the truck, not in the skill lane.
- Decontaminate the exterior as required, then mark and label: SALVAGE, proper shipping name, consignee, hazard labels. Shipping papers if it will move under HMTA rules (173.3(c)(5)).
- Report effectiveness. The inner leak is not “fixed”; it is nested.
If the inner package is too deformed to lift, the IAP may be pump-off / transfer (11.4.3.4) or leave it in a diked area for a contractor, not a six-person deadlift in chemical suits.
Radioactive Type A and Type B packages — survey, labels, humility
Class 7 packages in 49 CFR 173 Subpart I include excepted, industrial, Type A, and Type B designs. In broad, citable terms: Type A packages are built to retain contents under normal conditions of transport; Type B packages (including Type B(U) and Type B(M)) are built to survive accident conditions of transport. That is enough package-type language for this JPR. Do not invent Nuclear Regulatory Commission (NRC) 10 CFR 71 clause numbers, activity limits, or “Type C” rules you cannot cite.
JPR 11.4.3.3 still expects technicians to overpack leaking radioactive packages using trained procedures:
- Survey with an appropriate radiation instrument before you commit hands, during movement, and after the recovery package is closed. Control zones follow the readings, not the color of the box.
- Time, distance, shielding, and PPE appropriate to contamination versus shine. A wipe that shows loose contamination is a different problem than a sealed source with a high dose rate and no leak.
- Do not destroy required markings or package integrity more than needed. Cut a strap if you must; do not grind off RADIOACTIVE, contents, activity, or transport index markings to make the box fit a drum.
- Maintain labeling. If the inner Type A/B marks will not be visible, the recovery enclosure has to carry the required Class 7 labels and marks so the next person is not handling an anonymous drum. When the legal instrument is a 173.25-style overpack around a still-functional inner package, OVERPACK plus visible-or-duplicated Type A/B information is the 173.25(a)(4) idea. When the inner is a leaker going into salvage packaging, SALVAGE plus the prescribed radioactive labels is the 173.3 idea. Either way, the hazard communication stays on the outside.
- If your unit does not have radioactive overpack procedures, instruments, or a qualified radiation authority, OSHA (q)(6)(iii)(F) again limits you to available resources — isolate, deny entry, request a radiological response team. That is still a correct technician decision.
Scenario: warehouse drum versus a dented Type A box
Scene 1 — CDP drum over-packing. A 55-gallon tight-head drum of identified flammable liquid has a sidewall puncture. After a compatible plug (9.3) still weeps, the IAP is overpack: 85-gallon UN 1A2 open-head salvage drum, absorbents in the bottom, rotate leak-up, set the drum, more absorbent, bolt ring, SALVAGE plus flammable-liquid labels and the shipping name. That nested package is salvage packaging under 173.3(c), not a claim that the inner UN mark is back in force.
Scene 2 — leaking Type A radiopharmaceutical package in a hospital receiving dock. Survey first. If contamination is local and the procedure and packaging exist, place the package in the designated radioactive recovery/overpack so labels remain correct and readable, without crushing the inner containment more than the procedure allows. If the dose rate or contamination is beyond the hospital team’s protocol, isolate and bring in the people who own the meters. Do not “make it Type B” by putting it in a thicker drum, and do not scrape the Yellow-II label off because it would not lie flat.
When overpacking a leaking 55-gallon drum into a salvage drum, which orientation and closure practice matches NFPA 470 11.4.3.3 / CDP drum over-packing teaching?
Which statement correctly states 49 CFR 173.3(c) salvage-drum requirements used when shipping a recovered leaker?
How should a technician overpack a leaking radioactive Type A or Type B package under NFPA 470 11.4.3.3 without inventing NRC package-type trivia?