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Interpretation Response #98-0313 ([Hazmat Environmental Group, Inc.] [Ms. Nancy J. Copelin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazmat Environmental Group, Inc.

Individual Name: Ms. Nancy J. Copelin

Location State: NY Country: US

View the Interpretation Document

Response text:

DEC 3, 1998


Ms. Nancy J. Copelin                      Ref. No. 98-0313
Hazmat Environmental Group, Inc.
New Village Industrial Park
60 Commerce Drive
Buffalo, NY 14218-1040

Dear Ms. Copelin:

This is in response to your October 16, 1998 letter concerning the definition of "bulk packaging" as defined in the 49 CFR 171.8. Your question was further clarified in a phone conversation to request a definition of "maximum net mass" which is used to define a bulk packaging.

Your understanding is correct. If your receptacle is rated to hold more than 400 kg (882 pounds) and has a maximum net capacity greater than 450 L (119 gallons) then your receptacle is considered a bulk packaging even if your receptacle weighs less than 400 kg (882 pounds) at the time of shipment. The bulk packaging definition is based on the capacity of your receptacle, not on the actual amount contained therein at the time of shipment.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.8 Definitions and abbreviations