Tri-State Hospital Supply Corporation — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department OCT 3 2001 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration Tri-State Hospital Mr. Irent Sisco Ref. No. 01-0121 30409 Commerce Drive Supply Corporation San Antonio, FL 33576 Dear Mr. Sisco: This responds to your letter requesting clarification of the packaging exceptions for regulated medical waste (RMW) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). specification fiberboard packaging conforms to 49 CFR Specifically, you inquire whether your non-bulk, non- 173.134 (b) (3). You stated in a telephone conversation with a member of my staff that the RMW is transported by a private or contract carrier. The answer is yes. As provided by § 173.134 (b) (3), a regulated medical waste that is transported by a private or contract carrier is excepted from: (1) the "INFECTIOUS SUBSTANCE" label, if the outer packaging is marked with a "BIOHAZARD" marking conforming to 29 CFR 1910.1030, and (2) for other than a waste packaging requirements in S 173.197, if packaged in a culture or stock of an infectious substance, the specific rigid, non- bulk package conforming to SS 173.24 and 173.24a, and 29 CFR 1910.1030. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Meet Transportation Regulations Specialist Office of Hazardous Materials Standards . 173134 010121#

Page 2: MAY-11-2001 15:58 TSHSC r.хe ES LOSTAL SUPYLY CORPOBAZION Tri State 30409 Commerce Drive • San Antonio, FL 33576 Stevens (352) 588-3732 • (800) 775-8868 • Fax (352) 588-4899 3/73.141 CENTURION 173.134 Mr, Edward Mazzullo Regulated Medical Director of the Office of Hazardous Materials United States DOT/RSPA (DHM-10) 01-0121 Washington, DC 20590-0001 400 7th Street S.W. 5/11/01 Dear Edward, I need your help. I am writing on behalf of Tri-State Hospital Supply Corporation specifically in regards to the corrugated Biohazard boxes that we supply in the State of Florida. I had contacted Washington D.C. in regards to the printing of our They had instructed me that as long as I am compliant with the Florida Administrative Codes for Biomedical Waste that we would be in compliance with the Department of Transportation. After thoroughly reading the Florida Administrative Code for Biomedical Waste (Chapter 64E-16), it looks like we are is printed for all boxes at least six inches in diameter on outer containers 19" X 14" or larger, and at least one inch in totally compliant in regards to the printing of our boxes. For Outer Containers, the interational biological hazard symbol or number be printed on the boxes. In Florida, some boxes have a 4G or UN certification # on them and some do not diameter on outer containers less than 19"X 14". No where does it state that any kind of certification or regutation code have any certification #'s on them at all. It varies from place to place. Usually the waste management transporter prints a convenience. However, this is not required on the printing of the boxes because it is not mentioned in the Florida certification # on their boxes. They might do this so they do not have to put a label on them every time out of pure Administrative Code. From everything our company has read, we are totally in compliance. compliance with the D.O.T. as well because of the compliance with the State Codes. What our company needs is a Then we talked to the State of Florida and the D.O.T. and they said that we were compliant and that we would be in specific letter addressing that we are in compliance for the D.O.T. in regards to the printing of our corrugated containers any certification numbers for that matter does not need to be printed on the boxes that we supply in the State of Florida. for Biomedical Waste. And also if you could please specifically address that the following certifications, compliances and They might have to go on the side of the biohazard waste truck or a label that the generator or transporter puts on the case, then a lot of companies are not in compliance because about half the boxes just have the Biohazardous Waste boxes. However, no where can we find that any kind of certification number has to be printed on the boxes. If this is the Symbol printed on them. From reading the Florida Administrative Codes, it looks like labels satisfies any need to print anything other than the Bio-Hazardous Sign on the boxes. Could you please include in your letter that the following certification numbers or any numbers are not necessary to be printed on the boxes according to Florida Administrative Codeland also is not required to be compliant with the D.O.T.? And if indeed labels are required to have any certification numbers on them, then please specify that the labels should get printed and directly printing any certification numbers on the boxes is not necessary. Certification #'s 4G D.E.P. #7221 UN3291 u: 4G/Y15.8/S/99 N USA/+BR1826 Sectión 173.197 Complies with 49CFR Page 1 of2 Phoenix • San Francisco • Los Angeles • Denver • Tampa • Miami • Atlanta • Chicago • Indianapolis • New Orleans • Boston • Baltimore Detroit - Minneapolis - St, Louis • Kansas City • Omaha • New York - Syracuse • Salisbury • Columbus = Cleveland - Oklahoma City Phiadelphia • Pitsburgh • Memphis /Dallas • Houston a San Antonio a Scattle a Milwaukee#

Page 3MAY-11-2001 15:58 TSHSC P.03 HOSPITAL SUTPLY CORPORAITON Tri-State 30409 Commerce Drive • San Antonio, FL 33576 (352) 588-3732 » (800) 775-8868 • Fax (352) S88-4899 CENTURION Cerin son or neicatons are bied pried on ly lout if er in rase cat mer you nave any questions Sincere thanks for all of the help! Respectfully Yours, Trent Sisco Tri-State Hospital Supply Corporation • Page 2 of 2 Phoenix San Francisco • Los Angeles • Denver Tampa Miami • Allanta • Chicayo • Indianapolis New Orleans • Boston Baltimore Detroit • Minneapolis - St, Louis - Kansas City • Omaha;• New York • Syracuse • Salisbury • Columbus • Cleveland • Oklahora City Philadelphia • Pittsburgh • Mernphis - Dallas • Houston • San Antonio • Seattle • Milwaukee TOTAL P.03#