Interpretation Response #06-0083 ([Transportation Systems Solutions] [Mr. Peter Olsen])

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

Interpretation Response Details

Response Publish Date: 04/28/2006

Company Name: Transportation Systems Solutions

Individual Name: Mr. Peter Olsen

Location State: IL Country: US

View the Interpretation Document

Response text:

Apr 28, 2006

Mr. Peter Olsen                 Reference No. 06-0083

Transportation Systems Solutions

318 Hampshire Lane

Crystal Lake, IL 60014

Dear Mr. Olsen:

This is in response to your April 6, 2006 letter requesting clarification regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the shipment of empty packagings with residue. Specifically, you ask if the requirement in § 173.24(b)(4), which prohibits hazardous material residue from adhering to the outside of a package during transport, applies to an empty packaging with residue.

The answer is yes. The HMR do not allow any package to be transported with hazardous material on the outside surface. However, if a package containing hazardous material is emptied and some of the material is spilled on the outer surface of the packaging and dries, it may be transported if the dried residue does not meet the definition of a hazardous material and the package still meets the general packaging requirement in Part 173, Subpart B.

I hope this information is helpful.

Sincerely,

Hattie L. Mitchell, Chief

Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.24(b)(4)

Regulation Sections