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Interpretation Response #05-0256 ([WRR Environmental Service Company, Inc.] [Mr. Steven P. Stokke])

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

Interpretation Response Details

Response Publish Date:

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
178.604 Leakproofness test