Use of Empty Label
Pipeline and Hazardous Materials Safety Administration · Aug 20, 2001 · Reference No. 01-0169
Interprets: 49 CFR § 172.428, 49 CFR § 172.450
Reggie’s quick take
A packaging company asked whether the empty label required for an empty radioactive material package under § 173.428 can be used on a cleaned and purged package that once held a nonradioactive hazardous material. PHMSA said yes. A shipper may put the empty label shown in § 172.450 on an empty package that formerly held a hazardous material of any hazard class.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your letter dated June 29, 2001, requesting clarification of labeling requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the empty label required under § 173.428 for an empty radioactive material package may be used for a cleaned and purged packaging that formerly contained a nonradioactive hazardous material.
The answer is yes. A shipper may apply the empty label depicted in § 172.450 to an empty packaging that formerly contained a hazardous material of any hazard class.
I hope this satisfies your request.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.