Applicability of the U.S. DOT's Closure Notification Requirements to Shippers Who Transport Empty Containers Containing Hazardous Residues

摘要

We believe that 178.2(c) notification to recipients of type and dimension of closures and closure procedures for hazardous materials packaging applies to persons who ship hazardous materials in IBCs to recipients who then return the IBC, with hazardous material residues, for reuse. 1. Does this apply also to drums, canisters, carboys returned with residual hazardous material, intended for reuse? 2. Does this apply to packaging to be returned with residual hazardous material for recycling of the container (i.e. cleaning and shredding of plastic containers)? 3. Does this apply to drums, canisters, carboys with residual hazardous material that are sent independently by the recipient for reuse, with no intention by the provider that they be used in that manner?