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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 #12-0023

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name:

Location State: GA Country: US

View the Interpretation Document

Response text:

March 7, 2012



Mr. T. J. McCaustland
Environmental, Safety, and Health Manager
SSWSI-East Region
583 Highway 162
Covington, GA 30016


Reference No.: 12-0023


Dear Mr. McCaustland:

This is in response to your January 12, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to overpacks.  Specifically, you present a scenario where you ship multiple drums of various size containing EPA Hazardous Waste code D001.  The Reportable Quantity (RQ) for D001 is 100 pounds and none of the drums exceed 99 pounds.  The drums are shrink wrapped to a pallet (overpacked) for shipment.  You ask whether the overpack meets the definition of a package, causing the shipment to be classified as a hazardous substance.   

The answer is no.  Multiple packages overpacked together do not meet the definition of a single package.  Shrink wrapping the individual drums (packages) to a pallet is specifically cited as meeting the HMR § 171.8 definition of Overpack.  Therefore the shipment as described would not be classified as a hazardous substance. 

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




Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

Regulation Sections

Section Subject
171.8 Definitions and abbreviations