Shipping empty Hazmat drums

You’re right in regards as still identifying them as HazMat even though they are empty. As far as the condition, man I dunno. I’d say that’s drivers discretion and if it’s too bad, hell with them. Refuse to pick them up until they clean em up. I mean the one thing you got going is it’s not corrosive lol
@MACK E-6 & @Bob Dobalina are my go to’s for LTL help. I just kinda wing stuff, they actually know what they’re doing.

 

That should fall under “residue last contained” in my opinion.

 

49 CFR § 173.29 - Empty packagings. (a) General. Except as otherwise provided in this section, an empty packaging containing only the residue of a hazardous material shall be offered for transportation and transported in the same manner as when it previously contained a greater quantity of that hazardous material.



US DOT Requirements for the Shipment of Empty HazMat Packagings - Daniels Training Services

 

I appreciate that, but I'm definitely still learning and this situation is a tough one.

From what I understand, only empty bulk containers are required to be placarded even if they are under the required weight (1,001# in this case for Flammable 3). Drums aren't "bulk" so there's that part. However, he's saying the total shipment weight of all the empty drums is 1,200# and I remember being told that the total weight counts even if the hazardous material itself inside weighs less than 1,001#.

I would think that particular shipment requires placards, but I'm gonna have to consult my hazmat guru at work tonight.

I was in a similar situation many years ago working for a non-hazmat carrier and without a hazmat endorsement. I picked up a few empty forklift batteries, which probably totalled well over 1,001# even without the liquid inside. I was assured it was cool, and I took them. I would certainly think twice about doing that now.

 

If you are hauling as many as you say then yes, placards are required and it should be the same as the drums, UN1866.
It is no different than the tank I pull, when I unload if must keep the placards on until it is washed out.

 

So it would appear there will be a need to placard the trailer with Class III, Flammable.

 

I consulted my guru. He said yes they are placarded due to the total weight and the fact that there's residue of the material still in the drums. They need Flammable 3 placards. UN# placards are not necessary because they aren't in "bulk packaging" as defined in the regs.