What type of protective cap must be placed on aerosols if you don’t remove the nozzle? Is this the case if they are shipped in a 55 gallon drum? Or only if shipped loosely?
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A. We found nothing in either the Hazardous Materials regulations at 49 CFR 173 or the interpretation letters provided by the Pipeline and Hazardous Materials Safety Administration (PHMSA) that defined the type of protective cap that must be used if shipping aerosol cans in compliance with 49 CFR 173.306(k).
According to 49 CFR 173.306(k), which provides a conditional exemption from the 30 kg (66 pounds) gross weight limitation when aerosols are transported by motor vehicle for purposes of recycling or disposal, “each aerosol container must be secured with a cap to protect the valve stem or the valve stem must be removed.” The exemption does not allow for the aerosols to be “shipped loosely” as you asked, as the regulation refers to “the strong outer packaging.”