Do empty hazmat containers need shipping papers?

Short answer

Empty hazmat containers generally need shipping papers, but there are exceptions.

The rule says

"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." (49 CFR 173.29(a))

"A non-bulk packaging containing only the residue of a hazardous material covered by Table 2 of 172.504 of this subchapter that is not a material poisonous by inhalation or its residue shipped under the subsidiary placarding provisions of 172.505 (1) Does not have to be included in determining the applicability of the placarding requirements of subpart F of part 172 of this subchapter; and (2) Is not subject to the shipping paper requirements of this subchapter when collected and transported by a contract or private carrier for reconditioning, remanufacture or reuse." (49 CFR 173.29(c))

In plain English

Empty hazmat containers usually require shipping papers because they still contain residue of hazardous materials, which poses a risk. However, if the container is being collected and transported for reconditioning, remanufacture, or reuse, and it's not a poisonous material, then shipping papers might not be required. The key is understanding the specific exceptions and ensuring the container meets those conditions. In practice, this means carefully reviewing the regulations and the container's contents to determine if shipping papers are needed.

What to do

• Review 49 CFR 173.29 to understand the requirements for empty hazmat containers.
• Determine if the container meets the exceptions for not requiring shipping papers.
• Ensure all necessary documentation, including shipping papers if required, is properly prepared and retained.
• Train personnel on the handling and transportation of empty hazmat containers to ensure compliance with regulations.