# Timothy Roberts — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 02-0033
- **title:** Timothy Roberts — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2002-03-07
- **effective on:** Not available
- **summary:** 02-0033 concerning 173.29.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0033.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0033.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0033
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020033.pdf
**body:**

<<<PAGE 1>>>

of Transportation
U.S. Department
400 Seventh St., S.W.
Research and
Washington, D.C. 20590
pecial Program
dministratio
MAR - 7 2002
Mr. Timothy Roberts
1106 Glendora Avenue
Ref. No. 02-0033
Oakland, CA 94602
Dear Mr. Roberts:
This is in response to your letter requesting clarification of
concerning the requirements in § 173.29 for empty packagings.
the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180)
Specifically, you ask whether cooking stoves and empty bottles
previously containing white gas are excepted from the HMR.
air prior to being offered for transportation and you plan to
state the stoves and bottles are drained and dried by exposure to
pack these items in your checked baggage.
Section 173.29 (b) (2). excepts
hazardous material from all HMR
an empty packaging that previously
it is cleaned of residue and purged of vapors so that no hazard
requirements provided
packaging are intentionally not defined in the HMR because
remains.
The methods that can be used to clean and purge a
vary greatly depending on the nature of the hazardous material
and the type of packaging.
emptied of hazardous material, including residue, without
In some instances, a packaging can be
undergoing a cleaning process
purged.
In other instances, an active cleaning process may be
and be considered cleaned and
necessary to clean and purge a packaging of hazardous residue.
Provided there is no residue or vapor meeting any of the hazard
bottles you describe in your letter are
class definitions in Part 173, Subpart D, the cooking stoves and
requirements of the HMR.
not subject to the
you need additional
I hope this information
assistance.
is helpful.
Please
contact this office if
Sincerely,
Transportation Regulations Specialist
Office of Hazardous Materials
Standards"
173.29(6)
020033

<<<PAGE 2>>>

MCIntyre
•
3173.29 (b)(2)01
January 2, 2002
Empty Packaglings
Edward Mazzullo
Division of Hazardous Material Standards
DHM-10
JS-DOT Research and Special Programs Administration
02-00 33
Washington, D.C. 20590-001
4007St. SW
Rear Mr. Mazzullo:
As a Safety Professional and an Assistant Scoutmaster (Troop 206, Oakland, California) 1 an
interested in getting an interpretation and clarification of a Department of Transportatior
requirement. As a Troop, we take an out-of-state backpacking trip during alternate summers.
When doing this, we normally plan to travel via a regularly scheduled commercial airline.
anywhere" matches on passenger aircraft, so we plan to obtain them when we arrive at our
We are fully aware that it is not allowed to carry cooking fuel (such as, white gas) and "strike
(these are one liter size aluminum bottles that we use them to carry the white gas during our
location. Our primary concern is the transport of our cooking stoves and our empty fuel bottles
hike). Our plan is to fully drain them, and allow them to air dry for approximately 24 hours prior
to our return flight. Prior to our trip to the location, we will empty the bottles and stoves and air
leave the caps off of the bottles and integral tanks on the stoves.
them out for approximately one month. We plan to check these on in our baggage and, of course,
exempt, under 49 CFR 173.29 "Empty Packagings" section (b)(2)(ii), but suggested that I contact
I recently had a conversation with a member of your staff, and that person indicated that these are
you for an official clarification letter that we can carry. with us in case any question arises at our
hesitate to contact me at (925) 423-3981.
departure airport. Should you have any question or need additional information, please do not
Thank you in advance for your attention to this matter.
Sincerely,
Auntale t
Timothy Roberts, CSP, CIH
1106 Glendora Ave.
Oakland, CA 94602
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