Comments on Current and Important DOT Interpretations of the Hazardous Materials Regulations

摘要

Section 173.28, letter dated June 4, 2004, to Mr. Chris Widman, Alliant Techsystems Inc. See page 47 of this issue for DOT'S letter I have always considered the reuse of fibre drums, and in particular, of fiber-board boxes, to be something that the regulations technically allow, but which, in practice, can almost never be done in compliance with the applicable requirements. For that reason this letter is both of interest, and one which, I believe, must be read very carefully in order to fully appreciate what it indicates is authorized under the regulations. These comments will address the guidance offered by DOT in this letter only in the context of reuse of UN 4G fiberboard "boxes".