Plastic Drum Reuse
Pipeline and Hazardous Materials Safety Administration · Feb 7, 1995 · Reference No. 95-0201
Interprets: 49 CFR § 171.14, 49 CFR § 173.21, 49 CFR § 173.24, 49 CFR § 173.28
Reggie’s quick take
Someone asked whether 55-gallon plastic drums can still be reused for hazardous materials. The agency says manufacturers can no longer make the DOT Specification 34 reusable polyethylene drum, and shippers could not use or reuse those drums in hazardous materials service after October 1, 1996. Drums dual-marked as both DOT Specification 34 and UN 1H1 or 1H2 must meet the UN standard in § 173.28 when reused, including its leakproofness pressure test. Rinsing is not required, but residue and new cargo must not reduce the package's effectiveness or create a danger, under §§ 173.21 and 173.24.
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 of November 3, 1994, regarding reuse of 55 gallon plastic drums.
As specified in § 171.14(b), manufacturers no longer are permitted to manufacture a DOT Specification 34 reusable polyethylene drum. Shippers may no longer use or reuse these drums in hazardous materials service after October 1, 1996.
Plastic drums that are dual-marked as representing both DOT Specification 34 and UN 1H1 or 1H2 standards must meet requirements for the UN standard in § 173.28 if they are reused. This includes the leakproofness pressure test specified in § 173.28(b)(2)(i). Although DOT does not require that a drum be rinsed before its reuse, provisions in §§ 173.21 and 173.24 prohibit placing materials (such as mixed residue and new lading) that could reduce the effectiveness of the package or create a dangerous situation.
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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.