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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 #09-0168 ([Baker Hughes] [Mr. Aubrey R. Campbell])

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

Interpretation Response Details

Response Publish Date:

Company Name: Baker Hughes

Individual Name: Mr. Aubrey R. Campbell

Location State: TX Country: US

View the Interpretation Document

Response text:

August 24, 2009

 

 

 

Mr. Aubrey R. Campbell

Baker Hughes

12645 West Airport Boulevard

Sugar Land, Texas 77478

Ref. No.: 09"0168

Dear Mr. Campbell:

This responds to your July 15, 2009 letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171"180) to the highway shipment of non-bulk drums containing only the residue of a hazardous material. You ask whether your shipment is eligible for the exceptions provided in § 173.29(c) and § 172.504(d).

The answer is yes. Generally, packagings containing a residue of a hazardous material must be transported in the same manner as when they previously held a greater quantity of the material. However, in accordance with § 173.29(c), a non-bulk packaging containing only the residue of a hazardous material covered by Table 2 of § 172.504 is excepted from shipping paper and placarding requirements when collected and transported by a contract or private carrier for reconditioning, remanufacture, or reuse. Furthermore, in accordance with

§ 172.504(d), except for hazardous materials subject to § 172.505, a non-bulk packaging that contains only the residue of a hazardous material covered by Table 2 of § 172.504 need not be included in determining placarding requirements. Provided your shipments meet these requirements, then you are eligible to utilize the exceptions provided in § 173.29(c) and

§ 172.504(d).

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.29(c), 172.504(d)

Regulation Sections

Section Subject
172.504 General placarding requirements
173.29 Empty packagings