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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 #99-0320 ([U.S. Marine Corps Air Station] [Mr. Dan Kesall])

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

Interpretation Response Details

Response Publish Date:

Company Name: U.S. Marine Corps Air Station

Individual Name: Mr. Dan Kesall

Location State: AZ Country: US

View the Interpretation Document

Response text:

December 8, 1999


Mr. Dan Kesall                        Ref.; No. 99-0320
U.S. Marine Corps Air Station
Facilities Management Department
Box  99140
Yuma, AZ 85369-9140

Dear Mr. Kesall:

This is in response to your letter dated December 7, 1999, concerning the definition of  bulk packaging" as defined in § 171.8 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically you ask if a bulk packaging may be filled with less than 400 kg (882 pounds) of a solid hazardous material and still be considered a bulk packaging.

The answer is yes.  If your packaging is rated to hold more than 400 kg (882 pounds) and has a maximum net capacity greater than 450 L (119 gallons) then it is considered a bulk packaging even if it weighs less than 400 kg (882 pounds) at the time of shipment.  The bulk packaging definition is based on the capacity of a packaging, not on the actual amount contained therein at the time of shipment.  There is no requirement under the HMR to fill a bulk packaging to greater than 400 kg (882 pounds).

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