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Please keep me informed as to any final decisions that may be made where this matter is concerned.

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We were very interested to learn that the U.N. Subcommittee on Drums are considering the drawing up of world wide specification for the use of Reconditioned Drums for hazardous and non hazardous products.

For your information and others Shell Canada buys new Spec. 17E drums made as follows - 18 gauge bodies, 18 gauge top heads and 16 gauge bottom heads. Through experience we have found that the bottom head of the drum takes the worst beating and by going to 16 gauge we have decreased our bottom chimb leakers.

About 11⁄2 years ago we also initiated a program at Universal Drum, our Reconditioner in this area, whereby the use of a power punch gun mechanism, we raise a small well around the 2" bung, every time the drum is reconditioned. The gun goes in the inside of the opening and raises a well around the outside of same. We now have many drums with five pimples or welts, some with six and a few with seven. We feel over a five year period we may end up with an interesting reuse number.

Shell Canada also uses a small amount of Spec. 5B 16 gauge drums, when regulations call for some.

You may be interested to know that we are presently purchasing from our Associates in the U.K. some 4000 drums of a special additive and we specify on our orders that the drums must be all 18 gauge and conform to C.T.C. Spec. 17E. This has been of tremendous help in replenishing our Reconditioned Drum Inventory. We further specify from people like Lubrizol Corp., when purchasing additives in U.S. and Canada that we require all 18 gauge drums, not 20/18. We will pay a premium for an all 18 gauge drum, to be able to reuse some in our system.

We do receive small quantities of lined and unlined 20 and 20/18's which we are unable to control. We have our Reconditioner segregate these and convert for grease use (non returnable) or we sell them outright to the Reconditioner as converters.

If we can provide any further useful information, please let us know.

Yours very truly,

W.H. White, Sr. Buyer

Standard Materials & Chemicals
Purchasing Department

March 13, 1974

Mr. William J. Burns, Director
Office of Hazardous Materials
Department of Transportation
400 Seventh Street, Southwest
Washington, D. C. 20590

Dear Mr. Burns:

I talked with you on February 4, 1974, and sent a letter dated February 5, 1974, to you concerning the reported meeting you were to have on February 8, 1974, with the Steel Shipping Container Institute representatives.

I turther promised, as Chairman of the Petroleum Packaging Committee of the Packaging Institute, U.S. A., to relay any information that might be of interest to you concerning the proposals being made by the SSCI when the Petroleum Packaging Committee met in St. Louis on February 25, 26, and 27, 1974. This meeting was held and considerable discussion developed over the future of the 55-gallon, style A, steel 17E drum.

The Chairman of our Large Container Subcommittee discussed this matter at some length; and, during the full committee meeting, we requested a vote by those member companies concerned with packaging petroleum products who preferred to use the full 18 gauge 17E, 55-gallon style drum. Out of 24 voting, 20 preterred continued use of the 18 gauge drum without modification. Four indicated they would be interested in using a full 20 gauge drum it developed by the steel drum manufacturers; however, it should be noted that these four users have only a one trip operation. In other words, these four users would not expect the container to be returned for reuse.

There were two interpretations placed on the reasons for SSCI's

appearance before you. One was that, in representing the steel drum manufacturing companies, SSCI was recommending the reduction in strength of all 55-gallon drums by modifying and changing the quality of 18 gauge drums, 18 gauge drums, 20/18 gauge drums and a recommendation that tests be made on a new container, 100ft 20 gauge 55-gallon drum. Of course, this plan would provide more drums in number due to the lesser amount of steel per drum. However, some of the members of

the Petroleum Packaging Committee have grave doubts that modified 18 gauge drums would conserve energy or money. In fact, limited usage of 20/18 gauge drums versus 18 guage shows very little difference in cost per drum and a very substantial increase in total cost when reconditioning is considered.

The other opinion of SSCI's appearance in your office was that they only wished to indicate the creation of a new container which was 20 gauge through out and that some of the present users of drums might find a use for this type container.

Mr. Arthur Nides was contacted by telephone by two of our members during the meeting and he explained the latter interpretation was intended. Were this the case, it would be all together commendable since it might serve well as a one trip sale and would not be subjected to reuse.

If SSCI expressed the latter development to be their reason for seeing you, then one might question why detailed changes to current specifications for standard 55-gallon drums were included in their agenda.

I believe this letter reflects the actual reaction which occured in the Petroleum Packaging Committee meeting on February 25, 1974.

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