Seatex Corporation — Hazardous Materials Safety Interpretation

Page 1100 Seventh Street. S.W Nashington, D.C 20590 Research and Administrations JAN 3 1 2001 Mr. Donald J. Trepel Ref. No. 00-0340 Director, Quality Assurance Seatex Corporation 6325 Hurst Street Houston, ' TX 77008 Dear Mr. Trepel: This is in response to your December 5, 2000, letter requesting clarification of shipping paper and placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if shipping papers and placards are required when empty non-bulk packages, which contain the residue of a hazardous material, are transported via a contract carrier to a drum reconditioner. Generally, empty packagings containing a residue of a hazardous material must be transported in the same manner as when they previously held a greater quantity of the material, unless the packagings are sufficiently cleaned and purged of vapors to SEATE remove any potential hazard, or are refilled with a material containing only the residue of a hazardous material covered by Table 2 of § 172.504 collected and transported by a contract or private carrier for reconditioning, remanufacture or reuse is excepted from the shipping paper requirements in Part 172, Subpart C. Therefore, if the shipment is made by a private or contract carrier, it is not subject to the shipping paper requirements ($ 173.29 (c) (2)). In addition, a non-bulk packaging containing only the residue of a hazardous material covered by Table 2 of § 172.504 is not subject to the placarding requirements in Part 172, Subpart F (§ 173.29 (c) (1)) . I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 173,29 000340#

Page 2BAH eatex OORPORATION §173.29(6)(2) Ipplicabilit Residuk December 5, 2000 00-0340 Mr. Edward Mazzullo Director, Office of Hazardous Materials Standards US DOT / RSPA (DHM10) 400 Seventh Street SW Washington D.C. 20590-0001 Dear Mr. Mazzullo: We will be contracting with a company to collect and transport our empty non-bulk packages to a drum reconditioner. Some of these packages contain the residue of a hazardous material. My question is, would (49CFR) 173.29 (c) (2) apply in this case? Or, would shipping papers and placarding be required? • Your guidance in this matter would be greatly appreciated. Sincerely, Gould Trepel Donald J. Trepel : • Director, Quality Assurance : Office: 713-868-1481 • Fax: 713-863-9240 • Toll Free: 800-829-3020 6325 Hurst Street • Houston, Texas 77008 Website: http://www.seatexcorp.com#