Interpretation Response #05-0256
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Dec 6, 2005
Mr. Steven P. Stokke Reference No. 05-0256
WRR Environmental Service Company, Inc.
5200 State Road 93
Eau Claire, Wisconsin 54701
Dear Mr. Stokke:
This is in response to your September 2, 2005 letter and subsequent telephone conversation with Mr. Cameron Satterthwaite of my staff regarding the packaging reuse provisions for steel drums in § 173.28 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that the steel UN1A1 drums are made of other than stainless steel. Your questions are paraphrased and answered as follows:
Q1. A UN1A1 drum containing residue is returned to our company from a distributor for refilling. May we refill the drum with the same product and return it to the distributor without performing a leakproofness test?
Al. No. A steel drum may not be reused without leakproofness testing, as specified in § 173.28(b) (2). The provisions of § 173.28(b)(7)(iv) apply to stainless steel drums.
Q2. If a drum meets the general reuse inspection requirements in § 173.28, what level of testing is required?
A2. A drum, subject to leakproofness testing, must be tested to the criteria specified in
I hope this information is helpful.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 173.28||Reuse, reconditioning and remanufacture of packagings|