Interpretation Response #22-0036

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

Interpretation Response Details

Response Publish Date: 08/01/2023

Company Name: Haz-Mat One

Individual Name: Mr. Travis Hillmer

Location State: KS Country: US

View the Interpretation Document

Response text:

August 1, 2023

Mr. Travis Hillmer
General Manager
Haz-Mat One
1203 C South Parker Rd
Olathe, KS  66061-4200

Reference No. 22-0036

Dear Mr. Hillmer:

This letter is in response to your April 29, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of salvage drums used to transport leaking packages containing Packing Group (PG) I (great degree of hazard) hazardous materials.

We have paraphrased and answered your questions as follows:

Q1. You ask whether PG I packages found to be leaking in transportation—containing PG I hazardous materials—may be placed in a PG III (minor degree of hazard) ("Z" rated) salvage drum.

A1. Packages of hazardous materials that are damaged, defective, or leaking; packages found to be not conforming to the requirements of the HMR after having been placed in transportation; and hazardous materials that have spilled or leaked may be placed in a metal or plastic removable head salvage drum that is compatible with the lading and shipped for repackaging or disposal under the conditions as specified in § 173.3(c). In accordance with § 173.3(c)(1), the drum must be a UN 1A2 (removable head steel drum), 1B2 (removable head aluminum drum), 1N2 (removable head metal (other than steel or aluminum) drum), or 1H2 (removable head plastic drum), tested and marked for PG III (minor degree of hazard) (“Z” rated) or higher (i.e., "X", "Y", or "Z" rated) performance standards for liquids or solids and a leakproofness test of 20 kPa (3 psig).

Q2. You ask whether a PG II ("Y" rated) or PG III ("Z" rated) salvage drum is authorized for the transportation of PG I, PG II, or poisonous by inhalation (PIH) hazardous materials packages found to be leaking or damaged in transportation.

A2. The answer is yes. See answer A1.

Q3. You ask if a PG I package is placed in a salvage drum due to a leak or damage, whether the salvage drum must be rated for PG I ("X" rated) or may it be tested and marked for PG II ("Y" rated) or PG III ("Z" rated).

A3. See answer A1.

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

Sincerely,

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

173.3(c), 173.3(c)(1)

Regulation Sections