{"operation":"document","citation":"00-0296","title":"Hospitec — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-11-09","effective_on":null,"summary":"00-0296 response to Hospitec concerning 173.197.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0296.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0296.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0296","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000296.pdf","body":"<<<PAGE 1>>>\n\nU.S.Department\nof Transportation\nWashington, D C\n400 Seventh Street, S.W.\n20590\nResearch and\nSpecial Programs\nAdministration\nNOV - 9 2000\nMr. Christopher Hahn\nReference No. 00-0296\nVice-President, Sales\nHospitec\n285 Granada Road\nWest Palm Beach, FL 33401\nDear Mr. Hahn:\nThis is in response to your letters and conversations with members of my staff concerning the\nrequirements for a regulated medical waste packaging under § 173.197 of the Hazardous\nMaterials Regulations (49 CFR 171-180). Specifically, you asked if a plastic sharps container\nthat is puncture-resistant, leakproof, and has passed requirements in 49 CFR Part 178 at the\nPacking Group II performance level is required to have a polyethylene liner (red bag). You\nstate that the liner was shredded during each test.\nIf the use of a plastic liner is not necessary to that packaging's performance, such as to satisfy\nthe moisture or leak resistance criteria, there is no requirement under § 173.197 to use a liner.\nI hope this satisfies your request.\nSincerely,\nHathe R. Mittell\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nOct 13 D0 12:28p\nChristopher Hahn-Hospitec 561-833-9179\nP.1\n1à :\nt3m134\nReaulated Medical\nHospitec ne.\n.. Beyond tills.\nWaste\nFAX\n203 - 502 Bow Valley Trail\nCanmore Alberta\nCompany: D.0.J-\nCanada TIW IN9\nTcl: 403-609-4330\n5ax: 707-366-3012\nFax: 403-609-4337\nToll Free: 1-800-337-2885\nPages (Including Cover): 2\nEmail: office@hospitecinc.com\nCOVER\nDate: 10/13/00\nFrom: CHRIs HAnD\nReference:\nQUESTION REGARDINO REGULATES\nIN ERROR OR THE INFORMATION IS UNCLEAR, PLEASE NOTIFY US IMMEDIATELY BY TELEPHONE.\nTHIS FAX CONTAINS INFORMATION THAT IS PRIVILEGED AND CONFIDENTIAL IF YOU HAVE RECEIVED THS COMMUNICATION\nTAIL IS MY SULONA TINE RESUMMITINE TATE\nATTACHES QUESTION. I GRIGINAL SUMMITTRO\nTAIS QUESTION TO FILEEN FEDMONSON ON\nJuLy 26, J000 AND sAua NoS RECEIVEs\nA RESPONSE BACK. WOULD yOU BE KINO\nFENDOGA TO GIUE ME A RESPONSE AS yOUR\nEARLIRST CONVENIENCE, IT IS IMPONTANT THAT\nI HAVa TAHS INFONMATTON AS SOON AS POSSIBLEE,\nSO I CAN PROVIDE SOMETHING IN UNITINE TO\nMy CUSTUMERS TARE ARE REQUESDINA IT. DOT.\nBUT I NICO SOMETHINE AN\n§ NOT NECESSANY,\nUNITING TO SAMSFY MY CUSTUMERS , TANK 400.\nBEST REGAROS,\nPAMIC\n\n<<<PAGE 3>>>\n\nOct 13 00 12:28p\nChristopher Hahn-Hospitec\n561-833-9179\np.2\nEamnonson\n8 173.134\nHospitec Regulated Medical Waste\nOctober 13, 2000\nMr. Edward Mazzullo\nDirector of Hazardous Materials Standard\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St., S.W.\nDHM-10\nWashington, DC 20590-0001\nDear Mr. Mazzullo:\nI would appreciate some clarification in writing regarding the testing protocol used for the testing\n(red bag) be placed inside a puncture-resistant, leak-proof plastic sharps container that has passed\nof Group Il Packaging of Regulated Medical Waste. Is it required that a polyethylene plastic liner\nthe Packaging Group II Performance Standards?\nI would like to add, that when the festing of our containers was completed by Ten-E Packaging\nServices, it was reported to us that the plastic liners served no purposo, since the inside liner\nalso informed by two D.O.T. Enforcement Specialists that the inner liner was not written into the\nwould always fail, due to the fact, that it always shredded from the sharps material inside. I was\nprotocol, and was not necessary. Unfortunately, I found this out after the testing was completed.\nPlease send response to the following address: 285 Granada Road, W. Palm Beach, FL 33401.\nThank you for your help.\nSincerely,\naDar\nChristopher Hahn\nVice-President of Sales\nInnovations in Healthcare","truncated":false,"body_characters":3669}