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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 #99-0010 ([Blue Grass Chemical Activity] [Mr. Kirk Kopitzke])

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

Interpretation Response Details

Response Publish Date:

Company Name: Blue Grass Chemical Activity

Individual Name: Mr. Kirk Kopitzke

Location State: KY Country: US

View the Interpretation Document

Response text:

February 7, 2000


Mr. Kirk Kopitzke                            Ref. No. 99-0010
Environmental Officer
Blue Grass Chemical Activity
2091 Kingston Highway
Richmond, KY 40475-5008


Dear Mr. Kopitzke:

This is in response to your letter requesting a clarification on the use of a salvage drum under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if a salvage drum marked “UN lA2/X445/S” may be used as a single package for hazardous material solids.

Yes, a salvage drum marked “UN lA2/X445/S” may be used as a single packaging for a hazardous material solid when it is prescribed or permitted in the non-bulk packaging section specified in column (8B) of the § 172.101 Hazardous Materials Table (HMT) for the material being packaged.  As with any UN standard packaging, the packaging must be compatible with the lading (e.g., corrosivity, permeability) and, the performance level for which the packaging has been tested (e.g., packing group, gross mass) may not be exceeded.  See §§ 173.24 and 173.24a.

To avoid confusion, the word “SALVAGE” marked on the drum may be removed or covered when offered for transportation under these circumstances.  If a UN standard drum is to be reused, it must conform to the reuse conditions specified in § 173.28 prior to being refilled.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standard


Regulation Sections

Section Subject
173.3 Packaging and exceptions