Reuse of uncontaminated explosives packaging

May 5, 1995

Mr. T.P. Dowling, P.E. Manager, Technical Services
Institute of Makers of Explosives
[Recipient address omitted]
Dear Mr. Dowling:

Thank you for your letter of May 2, 1994, regarding explosives' packing materials. Please accept our sincere apologies for the delay in our response which was due to reasons beyond our control.

In your letter you have inquired whether uncontaminated and safe packing materials used for packaging explosives could be reused or disposed of using methods other than burning. OSHA Standards (29 CFR 1910.109(e)(2)(i) and 1926.900(l)) require that packing materials which were used for packaging explosives must be burned. Based on the information that you have provided, however, we agree with your assessment that the reuse of such packaging material would not necessarily pose a safety problem.

As you have indicated in your letter, these regulations were designed to prevent the accumulation or improper disposal of explosive-contaminated packaging materials which could create a safety hazard. At this time, however, OSHA is aware that the subject standards require some interpretation to reflect the new technology and to be consistent with the other regulatory agencies, and newer consensus standards.

OSHA would regard the recycling, reuse, or disposal of uncontaminated packaging as acceptable and in keeping with the intent of the standards, so long as the packaging materials meet the requirements specified by USDOT in 49 CFR and present no safety hazard to personnel required to transport, handle or use the explosives, or to dispose of the packaging by means other than those required by the OSHA Standards.

Thank you for bringing this matter to our attention. We hope that you find this response helpful. If we can be of further assistance, please contact Alcmene Haloftis of my staff at 202-219-8031.

Sincerely,

John B. Miles, Jr., Director
Directorate of Compliance Programs

Attachment

[Requester letter reproduced on OSHA page; omitted here.]