empty packaging

Q&A: My HazMat packagings have been emptied and rinsed. Are they OK to ship as non-HazMat?

Q&A: My HazMat packagings have been emptied and rinsed. Are they OK to ship as non-HazMat?

Question (03.17.21):

Hi Daniel,

We have a customer who wants to ship empty containers to a container cleaning center. The totes and drums are empty and have been rinsed. Those containers had hazmat materials, can they cover up the labels and ship them ?

Regards,

Answer (03.17.21):

Thank you for contacting me. Please see below.

There are two options for the transport of these packagings in compliance with the Hazardous Materials Regulations (HMR) of USDOT/PHMSA:

Option 1: No Hazard

  • The transportation of a packaging is not subject to the HMR under the following conditions:
    • It is unused.
    • It has been cleaned of residue and purged of vapor to remove any potential hazard.
    • It has been refilled with non-HazMat so no hazard remains.
  • Under any of the above conditions the packaging is excepted from the HMR and may be transported as non-HazMat if the following is done:
    • All hazard communication (labels, marks, etc.) indicating the packaging contains a hazardous material are removed, obliterated, or securely covered.

Or…

    • The packaging is not visible during its transportation and it is loaded by the shipper and unloaded by the receiver or shipper.

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Option 2: The Empty Packaging Exception

  • If any HazMat residue remains the packagings may still be transported under the empty packaging exception. Compliance with the empty packaging exception requires the following:
    • It is a non-bulk packaging with a maximum capacity of no more than 450 L (119 gal).
    • It meets the USEPA criteria for RCRA empty with no more than 2.5 cm (1 in) of residue.
    • It is a HazMat found in Placard Table 2 at 49 CFR 172.504(e).
    • Transportation is by a private or contract motor carrier. Transportation by a common carrier is not eligible for the full empty packaging exception.
  • If the consignment is eligible for the full empty packaging exception, compliance requires the following:
    • It is not required to display placards on the vehicle.
    • It is not required for the shipper to prepare a shipping paper.
    • Package marks and labels are required to be displayed on the packaging the same as if it is full.
    • All other requirements of the HMR remain, e.g., HazMat Employee training.
  • If the consignment is eligible only for the partial empty packaging exception, compliance requires the following:
    • It is not required to display placards on the vehicle.
    • The shipper must prepare and sign  a shipping paper that describes the consignment as a hazardous material.
    • Package marks and labels are required to be displayed on the packaging the same as if it is full.
    • All other requirements of the HMR remain, e.g., HazMat Employee training.

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You indicate the packagings are empty and have been rinsed. The question to be answered is this:

Have they been emptied and rinsed to remove any potential hazard?

  • If yes, then the packagings may be offered for transportation as described in Option 1.
  • If no, then either the full or partial empty packaging exception described in Option 2 is available.

I hope this helps. Please contact me with any other questions.

That did it!:

Hi Daniel,

Thanks for the information and the links, this really helps.

Q&A: Must I display the HazMat’s identification number on my vehicle when transporting (essentially empty) IBCs?

Q&A: Must I display the HazMat’s identification number on my vehicle when transporting (essentially empty) IBCs?

A question 11.22.21:

Hello I have been asked to transport IBC containers containing trace (essentially empty) amounts of several types with id #1789/1790/1835/2031 am I correct in assuming they should still be identified by their numbers on the outside of my trailer even though they are in small quantities? I am in New York…

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
My answer:

You are correct. A bulk packaging (e.g., IBC or intermediate bulk container) that contains even trace amounts of a HazMat is subject to full USDOT regulations. This includes but is not limited to the following:

  • Placards and the HazMat’s identification number displayed on all four sides of vehicle.
  • Hazard communication including labels & marks on the packaging.

Read: Hazard Communication Options on the Intermediate Bulk Container

Read: USDOT/PHMSA Regulation of Empty Packagings with Residue

Please contact me with any other questions.

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Conclusion:

Another driver with a question. I’m glad he/she contacted me and I’m glad I was able to answer their question. HazMat transportation is too important to risk a non-compliance.

Scope and Applicability:

The above answer is derived from the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).

 

Q&A: How do I transport empty DOT 406 bulk fuel cargo tanks from Europe to U.S.?

A question from a soldier in the U.S. Army on July 20, 202o:

CLASSIFICATION: UNCLASSIFIED

Hello Daniels Training Services, INC. Team,

I read through your internet article USDOT Requirements for Shipments of Empty Packagings. Thanks for posting it.

I have a couple of questions on behalf of the US Army Europe.

Situation: We have DOT 406 Bulk Fuel Cargo Tanks that must be returned to numerous Army bases across the USA from Europe. The tanks have contained fuel and have been completely drained (including pipes, pumps and removal filtering systems) according to the manufacturers technical manuals. There may be “Crevice” residue fuel trapped in pipe connection seals that is undrainable. We will use military vessels to get them back from Europe to the nearest port in the USA. The tanks will have onward shipping by commercial trucks to their final destinations in the USA. We find no examples or provisions in the 49 CFR 171-173 that define “Cleaning/Purging” certificates or statements. We want to make sure that the “Cleaning/Purging” certificate statement we prepare here in Europe is acceptable for commercial carriers in the USA to authorize them to carry these Bulk Fuel Cargo tanks as a Non-Hazardous Material shipment.

Question 1. What resource document tells me the “SHIPPER” is responsible to know the exact provisions (standards) of what is meant by sufficiently cleaned of residue and purged of Flammable Liquid Vapors” for the below fuel types?

Question 2. Must tanks be cleaned with liquid substance?

Question 3. Or is “Draining all liquids & ventilating vapors below LEL levels to satisfy both terms, “Sufficiently Cleaned of Residue and Purged of Flammable Liquid Vapors” even if the temporary LEL of 0.00%(V) id recorded?

Critical LEL & UEL for the following fuel types:
HazMat DescriptionLower Explosive Limit (LEL)Upper Explosive Limit (UEL)
UN1202, Diesel fuel0.6%(V)7.5%(V)
UN1203 Gasoline/MOGAS1.4%(V)7.6%(V)
UN1223, Kerosene / JP-4 / NATO F-401.3%(V)8.0%(V)
UN1863, Fuel, aviation, turbine engine / JP-80.7%(V)5.0%(V)

As you can see above, all these fuels have different Lower/Upper Explosion Limits.

Question 4. Would you recommend that we set the standard with a LEL of 0.00% (V)?

Purpose of your efforts will help us establish a template certificate “Drain/Clean/Purge” statement for Fuel Cargi Tanks shipping for Soldiers returning from missions in support of the US Army in Europe.

Thank you in advance for any assistance you may provide us.

Interested in a Webinar that covers this topic, and more!

My Webinar Training Schedule
My reply that same day:

I will review and reply.

He was able to wait:

Mr. Stoehr,

Thank you, standing-by.

My final answer 06.21.20:

Please see below. My answers – like the article you referred to earlier – are derived from the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the US Department of Transportation (USDOT/PHMSA). The transportation in commerce of a hazardous material to, from, or through, the U.S. is subject to the HMR.

Question 1:

  • There is no clear regulatory citation on this specific point in the HMR.
  • 49 CFR 171.8 identifies the person who offers or offeror of a hazardous material (aka: the shipper) as a person who performs or is responsible for performing a pre-transportation function (described at §171.1(b)) or makes the HazMat available to the carrier.
  • The shipper is responsible for compliance with §173.29 Empty packagings as it is with the remainder of part 173.
  • The shipper must determine if the consignment is a HazMat and if so, what type and then communicate that information to the carrier. This requires the shipper to determine if a packaging, “Is sufficiently cleaned of residue and purged of vapors to remove any potential hazard”, or “Is refilled with a material which is not hazardous to such an extent that any residue remaining in the packaging no longer poses a hazard;”
  • In sum: There are no examples or provisions in the HMR for  cleaning or purging certificates or statements.

Question 2:

  • This is easier. No.
  • 49 CFR 173.29(b)(2)(ii) requires the packaging to be, “…sufficiently cleaned of residue and purged of vapors to remove any potential hazard;” it does not prescribe how to do this.

Question 3:

  • The HMR do not reference the LEL or UEL.
  • It is up to you as the shipper to ensure compliance with §173.29. The HMR does not indicate how you do this.

Question 4:

  • I do not recommend you set the standard with a LEL of 0.00%(V) since that is not indicated as a standard at §173.29.
  • Instead, I recommend you ensure compliance with the conditions of §173.29.

Purpose:

I think it a good idea to draft a “certificate of drain/clean/purge” though one is not required by the HMR. In my experience, most carriers wish to see one if they suspect the presence of HazMat.

I hope this helps. Please contact me with any other questions.

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Conclusion:

That was the last I heard from him. I hope the project went well. This is a common question among shippers of hazardous materials: How do I ensure the packaging is empty per 49 CFR 173.29? What certification is required? The answer is this: It is up to the shipper to determine if a packaging is in compliance with the requirements of 49 CFR 173.29 and then to offer it for transportation accordingly.

Q&A: Can my customer return empty HazMat packagings to me for reuse?

Q&A: Can my customer return empty HazMat packagings to me for reuse?

eMail of May 13, 2020:

As discussed on the phone this afternoon, <<Company>> is a specialty chemical company supplying a wide range of Industrial Chemicals, some of which are considered hazardous (most because they contain either caustic or acidic components for cleaning or pretreatment). We have a customer that wants to return the empty drums so we can refill them with the same product as a cost savings for both our customer and us. My question is what does the customer need to do prior to shipping them back to us via common carrier. In our phone conversation you mentioned that the drums needed to be “RICRA Empty” less than an inch remaining in the drum and they did not need to be triple rinsed and they could leave the original labels on the drum. Let me know what else needs to be done in order for the customer to return these drums and what paper work is needed in order to return the drums.

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
My reply May 14, 2020:

Thank you for contacting me. I apologize for not getting this to you last night. Please see below for answers to your questions.

USEPA Regulations:

  • The first responsibility of your customer(s) is to ensure the drums are RCRA Empty as that term is regulated by USEPA. This ensures the drums and any remaining residue are not subject to USEPA regulations (and most states) as a hazardous waste. In brief, RCRA Empty requires both of the following:
    • Get all HazMat out that can be gotten out using common practices (e.g., gravity flow when tipped, pump, etc.).
    • No more than 2.5 cm (1″) of residue remains on the bottom of the packaging. (Customer should get more out if they can).
  • This is important to you. If you receive and process drums that are not RCRA Empty you could be fined for unpermitted processing of a hazardous waste.
  • Triple rinse is not required to get a drum RCRA empty.Empty drums stored outdoors
  • Some states (California) have a more strict requirement for a drum to be considered empty.
  • Once RCRA Empty the drums should be closed tightly and stored in an area where they will not contribute to storm water pollution. (Try to keep them indoors if possible, no residue on outside).

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

USDOT/PHMSA Regulations:

  • When offered for transportation, your customer will be subject to USDOT/PHMSA regulation as a shipper of a hazardous material. You will be subject to regulation as the carrier.
  • If customer is able to remove all hazards (triple rinsing is not specified, a single rinse may suffice), then drum is not subject to USDOT/PHMSA Hazardous Materials Regulations (HMR). It is up to the shipper of the HazMat to determine if all hazards have been removed. The carrier should confirm this before accepting the consignment.
  • If any residue of the HazMat remains, customer must comply with USDOT regulations of 49 CFR 173.29. This is summarized below:
    • All USDOT  labels and marks must remain on drums. Customer may need to replace missing or damaged USDOT labels/marks.
    • Labels and marks not required by USDOT regulations (e.g., OSHA pictograms, product name) may be removed or may remain.
    • If all of the following are true, consignment of RCRA Empty drums does not require placards to be displayed on the truck (however, all other requirements of the HMR remain):
      • Non-bulk packaging (e.g., a drum).
      • A HazMat found in Table 2 at 49 CFR 172.504 (e.g., Class 8 Corrosive).
    • If the consignment is also transported by a contract or private carrier, then a shipping paper is not required either.
      • Contract carrier performs transport under terms of contract.
      • Private carrier is owner of HazMat in transportation, is not a third person transporter, and does not transport for hire.
    • If consignment is transported by common carrier, then shipping paper is required. (In your phone call you mentioned a common carrier).
      • Common carrier is JB Hunt, Schneider, Conway, &etc.
      • Shipping paper may include: “Residue last contained…” with proper shipping name.
    • Regardless of above, all other requirements of USDOT/PHMSA Hazardous Materials Regulations remain including HazMat Employee training for all involved in transport.
  • Once you receive the drums you may prepare them for reuse according to the HMR of USDOT/PHMSA.
In sum: if your customer can get the drums RCRA Empty, the drums can be transported back to you (USDOT regulations vary) for reuse and return to customer.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
I hope this helps. I am in the office today. Please contact me with any questions.
Q&A: Do I need special paperwork that shows my truck has been cleaned and washed before transporting?

Q&A: Do I need special paperwork that shows my truck has been cleaned and washed before transporting?

A question I received back on November 17, 2017:

I have a company that wants me to haul a used fuel truck that has hauled gas and diesel fuel they say it has been empty and setting in a storage lot for a period of time. Do I need special paperwork that shows that this truck has been cleaned and washed before transporting?

A pretty common question, so I was able to respond that same day:

Thank you for contacting me.  Please see below.

  • No.
  • It is the responsibility of the shipper (in this case the company that asked you to haul the fuel tank truck) to ensure that a packaging contains no residue of a HazMat and no dangers from it.  In the case of a Class 3 flammable liquid (gasoline & diesel) this would mean the absence of vapors.  The shipper does not need to provide a certification that the tank truck has been cleaned and purged.
  • It is the responsibility of the carrier (you) to reject a shipment if it is not in compliance with the regulations.  e.g. it is classified as non-HazMat but contains the residue – or vapors – of a class 3 flammable liquid and is therefore HazMat.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

In sum:

You may accept the cargo tank for transport as non-HazMat based solely on the certification of the shipper.  However, I highly recommend that you or your driver ensure there is no HazMat residue – not even vapors – in the cargo tank.  If any concern at all you should reject the shipment until it is rinsed, cleaned, and purged of all vapors so no hazard remains.  If this cannot be done it should be shipped as HazMat:  shipping paper, placards, HazMat Employee training &etc.
Please see below for more information:

Q&A: Is my tote a bulk packaging? Is it subject to regulation when shipped empty?

A question from a former coworker on August 29, 2017:

Good morning Dan. We have a client that has soaps coming to the facility that are corrosive in totes. They have contracted a recycling service to come pick up the empty totes. The service provider is being very conservative and wants to ship the totes as hazardous material, even though the totes are empty by normal practical means. They are stating the totes are 150 pounds each so when over six are shipped they are asking the client to provide placards for the shipment. The client is not DOT registered, they normally do not offer hazardous substances for transportation. Does the client take on liability for misrepresenting the shipment? (should not be shipped as a hazardous substance) I assume they would need to become registered and pay the annual fee, correct? If they only ship six totes (900 pounds), they would not require placarding and therefore would not need to be registered. However, if the transporter still wants to ship with a placard, could the client be responsible for misrepresenting the load by providing placards and signing shipping papers? Where is this addressed in the rules?

My reply that same day:

Thanks for contacting me.

  • Unless, “sufficiently cleaned of residue and purged of vapors to remove any potential hazard…” the packaging is subject to full regulation as a hazardous material when offered for transportation.  Read:  “Emptying” a Hazardous Material Packaging.  49 CFR 172.514(b) states this clearly for a bulk packaging.
  • There is an exception from full regulation for “empty” packagings that contain HazMat residue.  However, this exception does not apply to a bulk packaging.  I assume the “tote” you refer to is a bulk packaging.  Read:  Bulk Packaging for HazMat Explained!
  • Therefore, a bulk packaging containing any residue of a hazardous material must be shipped as a fully regulated HazMat.  This means that HazMat labels, marks, and/or placards are required on the packaging and on the vehicle as applicable.  A shipping paper describing the hazardous material must accompany the shipment.  All personnel involved in its off-site transportation must receive HazMat Employee training.UN3266 in Intermediate Bulk Container (IBC)
  • Any amount of a HazMat in a bulk packaging requires the display of placards on the vehicle.  It does not matter the weight of the HazMat nor the number of bulk packagings.  49 CFR 172.504(c) offers an exception for display of placards on a vehicle but not for bulk packagings or the really nasty HazMat of Placarding Table 1 at 49 CFR 172.504(e).
  • The shipper is responsible for the classification and shipment of the HazMat in compliance with the Hazardous Materials Regulations.  They will get the fine, not the carrier.

Options:

  • Ship empty totes as fully regulated HazMat.
  • Rinse out totes so no hazard remains.  Discharge wastewater down drain to POTW.  Then offer for transport.  No hazardous residue = no HazMat regulations.
  • Add chemical and/or absorbent to totes to neutralize Class 8 Corrosive.  No hazardous residue = no HazMat regulations.

Hope this helps.  Please contact me with any questions.

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It may not have been the answer he was hoping for but it did help:

Thank you so much Dan. I didn’t realize the totes were considered bulk packages and the “empty” definition does not apply. I’ve not really worked much with totes and I have learned something new again.

This really helps. Thank you.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services, Inc.

815.821.1550

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Q&A: What are the Shipper’s Responsibilities for the Transport of Diesel Residue in Fuel Tank Trailers?

Question to the Contact Me page of my website on March 7, 2015:

Combustible Placard with ID NumberLooking for guidance on the shippers responsibilities in reference to DOT hazmat regs when shipping empty 6,000 fuel tank trailers. The tank trailers have been re-built, pump tested, drained (but not triple rinsed), contain residual diesel fuel (50 gal or less) and will be loaded on another conveyance/trailer for transport (will not be towed).

My “Thanks and give me some time” response on March 9th:

That’s a good question. Let me do a little research and get back to you sometime later this week.

Questioner’s acknowledgement and a little more information (3.9.15):

Thank you Daniel.

We are being told the trailers must have a drain and purge certificate (be purged and triple rinsed) and hazmat certification documents prepared prior to shipment; however purging with water causes problems with the functionality of the tanker if it sets in storage for a while before shipment. The trailers are drained but there is residual diesel remaining in the pump filters, etc.

The Big Answer on March 13th:

What you describe (a 6,000 gal fuel tank trailer) is identified in the Hazardous Material Regulations (HMR) of PHMSA/USDOT as a Cargo Tank.  From 49 CFR 171.8:

Cargo tank means a bulk packaging that:
(1) Is a tank intended primarily for the carriage of liquids or gases and includes appurtenances, reinforcements, fittings, and closures (for the definition of a tank, see 49 CFR 178.320, 178.337-1, or 178.338-1, as applicable);
(2) Is permanently attached to or forms a part of a motor vehicle, or is not permanently attached to a motor vehicle but which, by reason of its size, construction or attachment to a motor vehicle is loaded or unloaded without being removed from the motor vehicle; and
(3) Is not fabricated under a specification for cylinders, intermediate bulk containers, multi-unit tank car tanks, portable tanks, or tank cars.

When a Cargo Tank is part of a motor vehicle it is identified as a Cargo Tank Motor Vehicle.  Also from 49 CFR 171.8:

Portable tank used to transport HazMat by highway

An example of a portable tank

 Cargo tank motor vehicle means a motor vehicle with one or more cargo tanks permanently attached to or forming an integral part of the motor vehicle.

Cargo Tank Truck of Compressed Gas

Example of a cargo tank motor vehicle.

So, what you describe is the transportation of a Cargo Tank that contains the residue of a hazardous material (I assume the diesel fuel is a Class 3 Flammable or Combustible Liquid).  The HMR regulates a packaging containing any residue of a hazardous material the same as if it was full.  There is an exception from some of the requirements of the HMR available to packaging with HazMat residue, but it does not apply to a bulk packaging as in this situation.

Available options:
  • Transport the HazMat residue-containing Cargo Tanks as hazardous materials subject to all of the requirements of the HMR.  This includes shipping papers, placards, HazMat labels, markings, HazMat Employee training, registration as a Shipper of HazMat, providing emergency information, &etc.
  • Remove all residue from the Cargo Tanks so that they are rinsed, cleaned, and purged of all vapors.  Then ship as non-hazardous.
  • Fill the Cargo Tanks with some non-hazardous material that is compatible with the residual diesel fuel so that the resulting mixture is non-hazardous.
I hope this helps.  Please don’t hesitate to contact me with any other questions.
Dan
Another grateful HazMat Shipper (though not yet a customer) on March 13th:
Daniel,Thank you so much for taking the time to research this issue and I really appreciate the guidance and options you provided.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

I receive and respond to questions like this all the time.  Let me help you with the questions you have about the transportation of hazardous materials.

Shipment of Empty Division 2.2 Compressed Gas Cylinders

When transported in commerce, a Division 2.2 Non-Flammable Gas must comply with all of the requirements of the Hazardous Material Regulations (HMR) of the US Department of Transportation.  When empty, a packaging of Division 2.2 Non-Flammable Gas is allowed to use an exception found at 49 CFR 173.29 that allows for the transportation of the empty packaging as a non-hazardous material, not subject to the HMR.  This is important, because 49 CFR 173.29(a) states the US DOT’s position that, besides exceptions to the regulation, like this one, an empty packaging containing residue is regulated the same as if the packaging was full; it reads,

Except as otherwise provided in this section, an empty packaging containing only the residue of a hazardous material shall be offered for transportation and transported in the same manner as when it previously contained a greater quantity of that hazardous material.

To use this exception to the HMR, the packaging must meet the following conditions:

  1. Packaging contains only the residue of a Division 2.2 Non-Flammable Gas.
  2. The gas is not ammonia, anhydrous.
  3. There are no subsidiary hazards associated with the gas.
  4. The gas is at a gauge pressure of <200 kPA (29.0 psig); at 20°C (68°F).
  5. No material in the packaging is a Hazardous Substance, Hazardous Waste, or a Marine Pollutant as defined at 49 CFR 171.8.

This means that as long as it meets the above 5 conditions, an empty Division 2.2 Non-Flammable Gas may be shipped off-site (eg. returned to the supplier for reuse) without the need for shipping papers, placards, labels, markings, trained personnel, etc.

As the shipper of an empty packaging of a Division 2.2 Non-Flammable Gas you are responsible to ensure that all markings, labels, and placards that identify the empty packaging as a hazardous material are removed, obliterated, or securely covered.  This is not necessary if…

  1. The packaging is not visible in transportation, and;
  2. The packaging is loaded by the shipper and unloaded by the shipper or consignee.  Per 49 CFR 171.8, “Consignee means the person or place shown on a shipping document, package marking, or other media as the location to which a carrier is directed to transport a hazardous material.”

The transportation of hazardous materials can be tricky.  Sometimes there is an exception like this one for certain hazardous materials, and sometimes there isn’t.  It’s up to you to know which regulations apply to your operations and how to comply with them.  Attendance at my HazMat Employee Training is a good way to learn what you need to know in order to safely ship hazardous materials.