Gloves and Textiles Containing Flammable Residue
Pipeline and Hazardous Materials Safety Administration · May 1, 1997 · Reference No. 97-0140
Interprets: 49 CFR § 172.101, 49 CFR § 172.102
Reggie’s quick take
Someone asked whether soiled gloves and oil- or gasoline-soaked textile rags picked up for recycling fall under federal hazardous materials rules, after a California law exempted them from state hazardous waste rules. The agency said the shipper must classify the material. If it fits no hazard class in Part 173, the federal rules do not apply. If free liquid can be seen around it, it may be a flammable liquid under § 173.120. If no free liquid is present, it may be a flammable solid under § 173.124. Materials with no visible free liquid at loading or closing may ship as "Solids containing flammable liquid, n.o.s., UN 3175, PG II" under Special Provision 47 in § 172.102.
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 February 12, 1997, concerning the applicability of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) as they pertain to transportation of soiled gloves and textile materials shipped for recycling.
Your company's trucks are used to pick up gloves, which contain a flammable residue, and reusable textile absorbent materials, soiled with oil and gasoline products. You stated that the California Senate Bill No. 419 (SB419) exempts the soiled gloves and reusable textile materials from the State requirements as a hazardous waste.
Under 49 CFR 173.22, it is the shipper's responsibility to properly classify a hazardous material. This office does not perform that function. If your soiled gloves and reusable textile materials do not meet any of the hazard class definitions provided in Part 173, including hazardous waste, hazardous substance, or marine pollutant, they are not regulated under the HMR. If free flowing liquid can be seen surrounding your materials, these materials may meet the definition of a flammable liquid in 49 CFR 173.120. If there is no free liquid surrounding these materials, they may meet the definition of a flammable solid in 49 CFR 173.124.
The entry "solids containing flammable liquid, n.o.s." in the Hazardous Materials Table, § 172.101 (§ 172.101 HMT), lists Special Provision 47 in Column 7. Under special provision "47," in § 172.102, mixtures of solids (e.g. gloves and reusable textiles) which are not subject to the HMR and flammable liquids (e.g., oil or gasoline) may be transported under the entry "Solids containing flammable liquid, n.o.s., 4.1, UN 3175, PG II," in the § 172.101 HMT, without first applying the classification criteria of Division 4.1, provided there is no free liquid visible at the time the material is loaded or at the time the packaging or transport unit is closed. Each packaging must correspond to a design type that has passed a leakproofness test at the Packing Group II level.
Placarding and training requirements applicable to hazardous materials shipments are prescribed in Part 172, Subpart F and Subpart H, respectively, of the HMR. Testing and licensing procedures for commercial drivers, prescribed in 49 CFR Part 383, are administered by the U. S. Department of Transportation's, Federal Highway Administration, Office of Motor Carrier Safety. You may contact them at 202-366-1790 or 5721.
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.