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Interpretation Response #17-0108

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

Interpretation Response Details

Response Publish Date:

Company Name: Lockheed Martin

Individual Name: Christian Calvo

Location State: CA Country: US

View the Interpretation Document

Response text:

January 02, 2018

Christian Calvo
Lockheed Martin
1011 Lockheed Way
MailDrop 6601
Palmdale, CA  93599

Reference No. 17-0108

Dear Mr. Calvo:

This letter is in response to your September 27, 2017, email and subsequent phone conversations requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the reuse of a non-bulk combination packaging.  You state that a vendor ships a Class 8 (corrosive) material in a combination packaging that consists of a sealed metal tank (inner packaging) and a 4H2 plastic box (outer packaging), to another location.  You also state that once the packaging arrives, the inner packaging is removed and replaced by an unserviceable metal tank of the same design for shipment back to the vendor.  Specifically, you ask whether the return of the combination packaging would be limited to one reuse without retesting or reconditioning per § 173.12(c)(5).

The answer is no.  Since the shipment does not contain a hazardous waste, the provisions of § 173.12 do not apply.  Provided the packaging does not show evidence of a reduction in integrity, one may continue to reuse the packaging.  Please see § 173.28 for the conditions and limitations for reuse of packagings.

I hope this information is helpful.  Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

173.12(c)(5), 173.12, 173.28

Regulation Sections

Section Subject
173.12 Exceptions for shipment of waste materials
173.28 Reuse, reconditioning and remanufacture of packagings