Reuse of Fiberboard Drums
Pipeline and Hazardous Materials Safety Administration · Jan 30, 1997 · Reference No. 97-0163
Interprets: 49 CFR § 173.28
Reggie’s quick take
A reader asked whether fiberboard drums can be reused under the hazardous materials rules. PHMSA said yes. The paper-reuse ban in § 173.28(b)(3) is aimed at paper bags, not fiber drums. Fiber drums may be reused, but only under the conditions and limits in § 173.28.
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 13, 1996 requesting clarification of the reuse provisions of § 173.28 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Specifically you ask whether fiberboard drums may be reused.
The answer is yes. The provision in § 173.28(b)(3) stating that "...packagings made of paper...are not authorized for reuse;" is intended to preclude paper bags from being reused. Fiber drums may be reused subject to the conditions and limitations of this section.
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.