There's no denying this can be done correctly, but....
http://www.tc.gc.ca/eng/tdg/clear-part5-300.htm#sec512
Classes 3, 4, 5, 6.1, 8 and 9 Dangerous Goods 5.12 Small Means of Containment
Beginning on January 1, 2003, all small means of containment used to contain dangerous goods included in Class 3, 4, 5, 6.1, 8 or 9 must be UN standardized means of containment. For small means of containment manufactured or marked in Canada, this is achieved by compliance with CGSB-43.146 or CGSB-43.150. These are the Canadian standards for UN means of containment for dangerous goods inClass 3, 4, 5. 6.1, 8 or 9. Non-UN means of containment, such as TC or DOT specification drums made before 2003, may be converted to the UN standards if they meet the requirements in CGSB-43.150.
(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 selected and used in accordance with sections 2, 3, 12 and 13 of CGSB-43.146 or sections 2 and 3 of Part I of CGSB-43.150 and sections 12 to 17 of Part II of CGSB-43.150. SOR/2011-60
(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
( b ) for a plastic drum, the requirements for the reconditioning, remanufacturing and repair in Part III 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. SOR/2011-60
These regs changed in 2011 ... would they not now preclude the re-use of 45 gal drums? In spite of the fact that we have been doing this for years AND it has been demonstrated that this practice can be executed safely?