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Interpretation Response #11-0135

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

Interpretation Response Details

Response Publish Date: 08-31-2011
Company Name: Veolia Environmental Services    Individual Name: Ms. Jennifer Eberle
Location state: NJ    Country: US

View the Interpretation Document

Response text:

August 31, 2011



Ms. Jennifer Eberle
Manager, Transportation Compliance
Veolia Environmental Services
1 Eden Lane
Flanders, NJ 07836

Reference No.: 11-0135

Dear Ms. Eberle:

This responds to your June 6, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the preparation for shipment of waste aerosol cans in accordance with the requirements for recycling or disposal of aerosols as specified in § 173.306(k) of the HMR. Specifically, you ask whether the marking requirements applicable to bulk containers in §172.302 apply when the aerosol cans are loaded in a UN specification bulk packaging (i.e.; an 11G fiberboard Intermediate Bulk Container (IBC)).

The answer is no. Under § 171.8, a "bulk packaging" is defined as a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous material are loaded with no intermediate form of containment. In your scenario, the waste aerosol cans in the 11G box would be a form of intermediate containment and, thus, not considered a "bulk packaging." Therefore, the bulk marking requirements in § 172.302 would not be apply to your package.

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

171.8, 173.306(k), 172.302

Regulation Sections

Section Subject
§ 171.8 Definitions and abbreviations