Timothy Roberts — Hazardous Materials Safety Interpretation

Page 1of 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 2MCIntyre • 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#