Reuse of Metal and Plastic Drums
Pipeline and Hazardous Materials Safety Administration · Aug 7, 1995 · Reference No. 95-0187
Interprets: 49 CFR § 173.28
Reggie’s quick take
A company asked how PHMSA's drum reuse rules apply to metal and plastic drums. The agency's answer covers what "same or similar contents" means, when plastic drums need thickness testing, and how thickness must be marked. Under § 173.28, a metal or plastic drum can be reused without leakproofness testing if it is refilled with the same material or a compatible one. Compatible means the materials do not react dangerously or harm each other or the plastic drum. Plastic drums meant for single reuse must be permanently marked with their minimum wall thickness. No test is prescribed, but a drum that is thinner than the required minimum may not be reused.
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 concerning marking and reuse provisions for metal and plastic drums. You requested clarification on three issues: (1) the meaning of "same or similar contents"; (2) when a plastic drum requires thickness testing; and (3) permanent embossment of this thickness.
Non-bulk packaging reuse provisions in 49 CFR 173.28 were revised in a final rule issued under Docket HM-215A (December 29, 1994; 59 FR 67390) and further revised in a final rule issued May 18, 1995 (60 FR 26796). Certain metal and plastic drums may be reused without being leakproofness tested if, as provided in § 173.28(b)(7)(i), the drum is refilled with the same material or a material which is compatible with that previously contained in the drum. Materials are considered compatible if they do not react dangerously with each other and would have no adverse effect on each other or on the plastic drum.
Plastic drums or jerricans intended for reuse or reconditioning as single packagings must be permanently marked with the minimum thickness of the packaging material, as determined in accordance with § 173.28(b)(4). No test is prescribed for determining drum thickness; however, the drum may not be reused if its thickness is less than the required minimum.
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.