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Interpretation Response #05-0256

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 12-06-2005
Company Name: WRR Environmental Service Company, Inc.    Individual Name: Mr. Steven P. Stokke
Location state: WI    Country: US

View the Interpretation Document

Response text:

Dec 6, 2005


Mr. Steven P. Stokke                           Reference No. 05-0256
Vice President
Operations Support
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
§ 178.604.

I hope this information is helpful.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

173.28, 178.604

Regulation Sections

Section Subject
§ 173.28 Reuse, reconditioning and remanufacture of packagings