Non-bulk packaging reuse provisions
Pipeline and Hazardous Materials Safety Administration · Aug 17, 1995 · Reference No. 95-0168
Interprets: 49 CFR § 173.28
Reggie’s quick take
Someone asked whether plywood boxes can be reused for hazardous materials. PHMSA's answer is yes, as long as the box meets all HMR requirements and can still pass the performance tests shown in its markings. This rule applies to non-bulk packagings, and it does not cover packagings made of paper, plastic, film, or textile. The letter also notes that under § 173.35(b), fiberboard, wooden, or flexible intermediate bulk containers may not be reused, while plastic, metal, and composite ones may be reused if they meet all HMR requirements.
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 and telephone conversation with Mr. Bill Gramer requesting clarification of the non-bulk packaging reuse provisions in § 173.28 (b) (3) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked if plywood boxes can be reused.
Except for packagings. made of paper, plastic, film, or textile, a 'non-bulk packaging, including a plywood box, may be reused as long as it conforms in all respects to the requirements of the HMR. The reused packaging must still be capable of passing the performance tests represented by the package markings.
Reuse provisions for intermediate bulk containers (IBCs) in § 173.35(b), state that fiberboard, wooden, or flexible IBCs may not be reused. Plastic, metal, and composite IBCs may be reused as long as they conform to all of the requirements of the HMR.
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.