Western Poly Drums, Inc — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 0 Seventh Street, S. ashington, D.C. 205 Special Programs Research and Administration OCT 1 8 1999 Mr. Floyd A. Whitney Ref. No. 99-0019 President 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 IA2 drums under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased 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. the drums have been previously used, that their reuse is However, the purchaser must be made aware that 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. Sincerely, Hate 2-Mithall Hattie I. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 990019 17328#

Page 2POLY EBRE STEEL WESTERN POLY WHY NOT PLACE YOUR NEXT ORDER ON-LINE? www.WesternPoly.com DRUMS, INC. 99-0019 A COMPLETE LINE OF UN. CONTAINERS & TANKS stevens $173.28 Mr. Delmer F. Billings Research and Special Programs Administration US Department of Transportation 400 Seventh St. S.W. Washington, D.C. 20590 January 19, 1999 Re: Reuse of Containers Dear Mr. Billings, Would you please send to me in writing the following: According to 173.28 (b) (6) and 173.12(c) We have a lot of used drums that have a UN rating of 1A2/Y1.4/150 or higher. They are new containers that have only been used once for a non- hazardous material. We check every drum to be sure that they are in very excellent condition. As I read solid, This 3s a non-bli, packaging not staget 1o the reco, for bring and ds and provisons of this section Am I correct in this scenario? Please let me know via fax and mail. Thank you, loyd A Whitne President 8727 ROCHESTER AVE., RANCHO CUCAMONGA, CA 91729-4200 (909) 466-9927 FAX 945-3075#