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DOT Confirms Closure Instructions Even For Empties

July 4th, 2006 by Howard Skolnik

Filed under: DOT/UN, HazMat

A recent inquiry to the DOT asked about the proper closure for transport of “empty” UN standard packagings (ie: steel drums, IBC‘s), which contain a hazardous material residue. This issue has sparked some debate in the Hazmat community because while packaging manufacturers are aware of the requirement to supply closure instructions, DOT is stating that the Closure Instructions must be followed whenever the packaging is transported, even after they have been emptied. DOT confirms that “empty” packagings are not excepted from CFR 173.24(f) and that they must be closed in accordance with notification as provided by the distributor/supplier. Even if being sent for disposal or reconditioning, these packagings must have correct closures and gaskets.

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