Interpretation Response #17-0108
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
January 02, 2018
1011 Lockheed Way
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
|§ 173.28||Reuse, reconditioning and remanufacture of packagings|