Interpretation Response #14-0136
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
October 24, 2014
Ms. Laura Buholca
5N Plus Wisconsin, Inc.
6474 Blanchar's Crossing
Windsor, WI 53598
Ref. No. 14-0136
Dear Ms. Buholca:
This responds to your July 11, 2014 request for clarification on the reuse of metal and plastic drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you need a wall thickness marking on the UN 1H2 drum (used as the outer packaging of a combination packaging) used to transport "UN3260, Corrosive solids, acidic, inorganic, n.o.s. (gallium trichloride), 8, PGII," under the reuse provisions in
In a conversation with a member of our staff in the Hazardous Materials Information Center (HMIC), you asked if the wall thickness marking is required to reuse a UN 1H2 plastic drum. The HMIC informed you that under § 173.28(b)(4) the wall thickness marking is required to be marked on the drum if it is the outer drum of a composite packaging or a single packaging. It is your understanding then that combination packaging is not required to be marked with the wall thickness under the reuse provisions in § 173.28(b)(4).
Your understanding is correct. In accordance with §§ 173.28(b)(4) and 178.503(a)(9), plastic drums used as single packagings or outer packaging of composite packagings and intended to be reused must be marked with the minimum wall thickness of the packaging material. Thus, a plastic drum of a combination packaging is not required to be marked with the wall thickness. The packaging scenario you illustrate is considered a combination packaging by definition and is not required to be marked with the wall thickness under the reuse provisions in § 173.28(b)(4).
I hope this answers your inquiry. If you need additional assistance, please contact this Office at (202) 366-8553.
Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
173.28(b)(4), 173.28(b)(4), 178.503(a)(9)
|§ 178.503||Marking of packagings|