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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 #20-0081

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

Interpretation Response Details

Response Publish Date:

Company Name: Stablex US ecology

Individual Name: Pierre-Olivier Gagné

Location State: QC Country: CA

View the Interpretation Document

Response text:

April 26, 2021

Mr. Pierre-Olivier Gagné
760 Boulevard Industriel
Blainville, QC J7C 3V4

Reference No. 20-0081

Dear Mr. Gagné:

This is in response to your September 30, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the authorization of United Nations (UN) 50AT metal Large Packagings.

Your questions are paraphrased and addressed as follows:

Q1. You ask whether the listed UN 50AT metal Large Packagings, authorized under the specified UN approvals, may be used as salvage containers for "UN1993, Flammable liquids, n.o.s., 3, PG II" materials in conformance with §§ 173.3(f) and 178.920 of the HMR. If not, you ask whether they may be used as salvage containers for this material in accordance with § 173.242(e).

  • UN 50AT/Y/D/BAM 14727-BAUER/4960/
  • UN 50AT/Y/D/BAM 14807-BAUER/6010/
  • UN 50AT/Y/D/BAM 14808-BAUER/6010/
  • UN 50AT/Y/D/BAM 14809-BAUER/6010/

A1. Except for transportation by air, § 173.3(f) permits packages of hazardous materials that are damaged, defective, or leaking; packages found to be not conforming to the requirements of this subchapter after having been placed in transportation; and, hazardous materials that have spilled or leaked may be placed in a large salvage packaging that is compatible with the lading and shipped for repackaging or disposal under certain conditions. These conditions include, but are not limited to, testing and marking in accordance with part 178, subparts P—which includes § 178.920—and Q at the Packing Group II or higher performance standards for large packagings intended for the transport of solids or inner packagings, and marked with the word "SALVAGE." In addition, § 173.242(e) is not applicable to this scenario as it does not pertain to the use of large packagings as salvage containers.

Q2. You ask whether your understanding is correct that a UN 50AT metal Large Packaging that is compliant with Transport Canada's Transportation of Dangerous Goods Regulations, incorporated by reference under § 171.7(bb), is authorized for use under the HMR when it conforms with §§ 171.22 and 171.23 of the HMR.

A2. The answer is yes, provided all the applicable provisions in §§ 171.22 and 171.23 are met.

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

Regulation Sections

Section Subject
171.22 Authorization and conditions for the use of international standards and regulations
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations
171.7 Reference material
173.242 Bulk packagings for certain medium hazard liquids and solids, including solids with dual hazards
173.3 Packaging and exceptions