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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #03-0136 ([CERAC Incorporated] [Ms. Candace Graf ])

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

Interpretation Response Details

Response Publish Date:

Company Name: CERAC Incorporated

Individual Name: Ms. Candace Graf 

Location State: WI Country: US

View the Interpretation Document

Response text:

Sep 12, 2003


Ms. Candace Graf               Reference No. 03-0136
Logistics Specialist
CERAC Incorporated
407 N. 131th Street
Milwaukee, WI 53233

Dear Ms. Graf:

This responds to your letter regarding requirements for reuse of packagings under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You asked if packagings may be reused for a material described as “Titanium tetrachloride, 8, UN 1838, PG II, Poison Inhalation Hazard, Hazard Zone B.” Subsequently, you provided information on the inner and outer packagings you intend using to ship this product.

In accordance with 49 CFR 173.28, except for a packaging made of paper, plastic film, or textile, a packaging, such as a UN IAI or UN IA2 steel drum, may be reused as long as it is in such condition that it conforms in all respects to the prescribed requirements under the HMR.  Metal drums used as single packagings or outer packagings of composite packagings are authorized for reuse only when they are marked with a minimum thickness in millimeters in a permanent manner (e.g., embossed). Packagings which are subject to the leakproofness test of 49 CFR 178.604 must be leakproofness tested prior to each reuse, unless otherwise excepted (see 49 CFR 173.28(b)(7)).

The pictures you provided are unclear.  The “inner packaging” is marked both with what appears to be a foreign manufacturer’s mark and a USA mark, “lA1/X/1.8/1240/03 USA M5142,” and the test pressure is not shown in kilopascals.  The letters "USA" may only be applied to a packaging that is manufactured in the U.S. We consider a packaging marked in the U.S. as having been manufactured and marked in the U.S. and suitable for bearing the “USA” symbol.  For single packagings intended to contain liquids, the test pressure must be shown in kilopascals rounded down to the nearest 10 kPa of the hydrostatic pressure test that the packaging design type has successfully passed. (see 49 CFR 178.503)

A packaging manufacturer conducts periodic retests as a quality control measure for newly
manufactured packagings.  During subsequent production of packagings of that design, periodic retests must be performed at least once every 12 months for single or composite packagings.  A test report must be completed for each packaging design qualification test and each periodic retest.  The requirements in 49 CFR 178.601 (1) set forth the information that must be included in each test report. A material described as “Titanium tetrachloride, 8, UN 1838, PG II, Poison Inhalation Hazard, Hazard Zone B,” must be packaged in accordance with § 1 73.227. Paragraph (c) of that section authorizes the use of certain single packages (UN 1A2, 1B1, lNl, and 6HA1, which may be used without being further packed in a UN 1A2 or 1H2 drum) that conform to the performance test requirements of subpart M of Part 178 at the Packing Group I performance level, and that:

(1)     comply with the applicable requirements of paragraph (b) of 173.227 (e.g., minimum thickness of a 1A1 steel drum with a capacity of greater than 30 L but less than or equal to 190 L is 1.08mm);

(2)     are loaded by the shipper - without double stacking the drurns - and blocked and braced within the transport vehicle and sealed in the transport vehicle; and

(3)     are shipped from one origin to one destination only without any intermediate pickup or delivery.

For materials poisonous by inhalation, a single or composite packaging authorized in 49 CFR 173.227 further packed in a “UN 1A2 of lH2” drum is not considered an “overpack.” An overpack as defined in 49 CFR 171.8 means an enclosure that is used by a single consignor to provide protection or convenience in handling a package or to consolidate two or more packages.

I hope this satisfies your inquiry.  If  we can be of further assistance, please contact us.



Susan G.Gorsky
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings