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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 #19-0020

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

Interpretation Response Details

Response Publish Date:

Company Name: Zee Company

Individual Name: Ricky Pruitt

Location State: GA Country: US

View the Interpretation Document

Response text:

May 30, 2019

Mr. Ricky Pruitt
Distribution Manager
Zee Company
307 Garrison Drive
Cleveland, GA  30528

Reference No. 19-0020

Dear Mr. Pruitt

This letter is in response to your February 18, 2019, letter and subsequent phone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to empty packagings. Specifically, you state that your company is hauling truckloads of 55 gallon drums and intermediate bulk containers (IBCs) containing the residue of "UN 1760, Corrosive liquids, n.o.s., Class 8, PGIII." You state these packagings are being transported in your company’s enclosed van trailers from one company location to another, where they would be reconditioned for future use.

We have paraphrased and answered your questions as follows:

Q1. You ask whether a shipping paper is required to transport 55 gallon drums containing only the residue of this material.

A1. The answer is no. Section 173.29(c)(2) states that a non-bulk packaging containing only the residue (see definition of residue in § 171.8) of a hazardous material covered by Table 2 of § 172.504 that is not a material poisonous-by-inhalation or its residue shipped under subsidiary placarding provisions in § 172.505 is not subject to the shipping paper requirements when collected and transported by a contract or private carrier for reconditioning, remanufacture, or reuse. If your company uses its own vehicles, you are considered a private carrier and shipping papers are not required.

Q2. You ask whether a shipping paper is required to transport 275 and 330 gallon IBCs containing the same residue. In addition, you ask whether the vehicles transporting these IBCs would require placards.

A2. The answer to both questions is yes. Section 173.29(a) states that in general, an empty packaging containing only the residue of a hazardous material shall be offered for transportation and transported in the same manner as when it previously contained a greater quantity of that hazardous material. There is an exception to placarding requirements in § 173.29(c)(1) which states that non-bulk packagings that contain only the residue of a Table 2 material from § 172.504 that is also not a material poisonous-by-inhalation or its residue shipped under the subsidiary placarding provisions of § 172.505 do not have to be included in determining the placarding requirements of Subpart F of Part 172. Because 275 and 330 gallon IBCs are bulk packagings, they are not excepted from placarding under § 173.29. Further, the shipping paper exception provided for in answer A1 applies to non-bulk packagings and not bulk packagings.

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


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

173.29(c)(2), 171.8, 172.504, 172.505, 173.29(a), 173.29(c)(1), 173.29

Regulation Sections

Section Subject
172.504 General placarding requirements
172.505 Placarding for subsidiary hazards
173.29 Empty packagings