Ask X3What does 49 CFR 173.12 (Exceptions for shipment of waste materials) require?
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Short answer
49 CFR 173.12 requires exceptions for the shipment of waste materials, including the use of open head drums for hazardous waste with solids or semisolids, and lab packs with specific weight and capacity limits.
The rule says
"If a hazardous material that is a hazardous waste is required by this subchapter to be shipped in a closed head drum (i.e., a drum with a 7.0 cm (3 inches) or less bung opening) and the hazardous waste contains solids or semisolids that make its placement in a closed head drum impracticable, an equivalent (except for closure) open head drum may be used for the hazardous waste." (49 CFR 173.12(a))
"The aggregate net weight per freight container, unit load device, transport vehicle, or rail car may not exceed 100 kg (220 pounds)" (49 CFR 173.12(b)(1)(iv))
"Lab packs conforming to the requirements of this section are not subject to the following: (1) The overpack marking and labeling requirements in 173.25(a)(2) of this subchapter when secured to a pallet with shrink-wrap or stretch-wrap" (49 CFR 173.12(f)(1))
In plain English
This rule provides exceptions for shipping waste materials, allowing for more flexible packaging options when the waste has solids or semisolids that make standard closed-head drums impractical. It also sets specific weight and capacity limits for lab packs and outlines marking and labeling requirements. In practice, this means that handlers of hazardous waste must carefully evaluate the properties of the waste to determine the appropriate packaging and ensure compliance with the specified limits and requirements.
What to do
- Evaluate the properties of the hazardous waste to determine if an open head drum or lab pack is suitable.
- Ensure that lab packs meet the specified weight and capacity limits.
- Verify that lab packs are properly marked and labeled, and that overpack marking and labeling requirements are met when applicable.
- Secure lab packs to a pallet with shrink-wrap or stretch-wrap when required.