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Interpretation Response #05-0226 ([PTP Consulting, Inc.] [Ms. Carol Brozosky])

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

Interpretation Response Details

Response Publish Date:

Company Name: PTP Consulting, Inc.

Individual Name: Ms. Carol Brozosky

Location State: NJ Country: US

View the Interpretation Document

Response text:

Nov 8, 2005


Ms. Carol Brozosky                        Reference No. 05-0226
PTP Consulting, Inc.
1531 Kings Highway
Swedesboro, NJ 08085

Dear Ms. Brozosky:

This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding § 173.12(c), which establishes a 24-hour holding time requirement for the reuse of packagings for the shipment of hazardous wastes. You ask whether the requirement applies to both non-bulk and bulk packagings.

Section 173.12(c) applies to non-bulk packagings only. With respect to bulk packagings, § 173.24 addresses the responsibility of the person offering a hazardous material for transportation, including ensuring that bulk packagings, as well as non-bulk packagings, do not leak; are compatible with the lading; and have no significant chemical or galvanic reaction between the materials and the contents of the packages. Further, § 173.24b contains additional requirements for bulk packagings; § 173.32 contains additional requirements specific to portable tanks; and § 173.33 contains additional requirements specific to cargo tank motor vehicles.

I hope this information is helpful. Please contact this office if you have additional questions.



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


Regulation Sections

Section Subject
173.12 Exceptions for shipment of waste materials