Are shipping papers required for empty drums going to a drum reconditioner?
Under CFR 173.29 (2) Is not subject to the shipping paper requirements of this subchapter when collected and transported by a contract or private carrier for reconditioning, remanufacture or reuse. MCS does require the shipper to fill out an “Empty drum certification form” agreeing to the following: • This is to certify that the above named materials are properly classified, described, packaged, marked and labeled and are in proper condition for transportation according to the applicable regulations of the DEPARTMENT OF TRANSPORTATION. (49 CFR 172.204} • It is further certified that all containers are empty: that all plugs, lids and rings are securely in place. (49 CFR 173.29) • It is further certified that all containers are properly classified, described and offered for shipment according to the applicable requlations of the ENVIRONMENTAL PROTECTION AGENCY (40 CFR Parts 260-263), and that they are EMPTY as defined in 40 CFR 261.7, and have not contained “acutely hazardous waste,” as
