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Interpretation Response #99-0019 ([Western Poly Drums, Inc] [Mr. Floyd A. Whitney])

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

Interpretation Response Details

Response Publish Date:

Company Name: Western Poly Drums, Inc

Individual Name: Mr. Floyd A. Whitney

Location State: CA Country: US

View the Interpretation Document

Response text:

October 18, 1999


Mr. Floyd A. Whitney                          Ref.  No. 99-0019
Western Poly Drums, Inc.
8727 Rochester Ave.
Rancho Cucamonga, CA 91729-4200

Dear Mr. Whitney:

This is in response to your letter dated January 19, 1999, regarding the reuse of UN 1A2 drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Your questions are paraphrased and answered as follows:

Question 1. May drums that have been used once for the transportation of non-hazardous materials be reused for shipment of hazardous wastes in a liquid or solid form?

Answer 1. Yes, the drums may be reused in conformance with the requirements in § 173.12(c), without meeting the reuse and reconditioning requirements in § 173.28. The use of open-head drums for shipment of liquid hazardous wastes must be in accordance with § 173.12(a). (The fact that the drums were previously used for non-hazardous materials is immaterial).

Question 2. Are we required to recondition these drums prior to their sale and reuse for packaging of hazardous waste?

Answer 2. No. However, the purchaser must be made aware that the drums have been previously used, that their reuse is authorized on a one-time basis for shipment of hazardous wastes, and any other reuse for hazardous materials must be in accordance with § 173.28.

I trust this answers your questions.  Please contact us if we may be of further assistance.



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


Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings