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Interpretation Response #11-0073 ([International Titanium Powder] [Mr. Bill Murphy er])

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

Interpretation Response Details

Response Publish Date:

Company Name: International Titanium Powder

Individual Name: Mr. Bill Murphy er

Location State: IL Country: US

View the Interpretation Document

Response text:

August 22, 2011




Mr. Bill Murphy

Supply Chain Specialist

International Titanium Powder

940 South Frontage Road

Suite 2000

Woodridge, IL 60517

Ref. No. 11-0073

Dear Mr. Murphy:

This responds to your March 17, 2011 email and subsequent telephone conversation with a member of my staff requesting clarification of the packaging reuse provisions of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). As indicated in your letter, you manufacture a titanium metal powder, which you class and described for transportation as "UN 3089, Metal powders, flammable, n.o.s., 4.1, PG II." The powder is transported in UN1A2 reconditioned steel drums designed to contain solids. The powder is placed in a low-density polyethylene (LDPE) liner with an inert gas, sealed, and placed inside the steel drum for transportation. The combination package is transported to an outside entity for processing. The outside entity unpacks the material, processes the powder, then repackages the material in the same drum and in the same manner as when it was originally packaged, except the outside entity uses a new LDPE liner. Specifically, you ask if the steel drum is required to be leakproofness tested prior to reuse in accordance with § 173.28.

The answer is no. Leakproofness testing in § 173.28 applies to a package originally required to be leakproofness tested. Generally, this is a package intended to contain liquids. Your drum is not subject to leakproofness testing under § 173.28 because it is used for solids and the design was not originally required to be leakproofness tested.

I hope this answers your inquiry. If you need additional assistance, please contact this office

at 202-366-8553.


Ben Supko

Chief, Standards Development

Standards and Regulations Division


Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings