Rubbermaid Commercial Products — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh St., S.W. of Transportation Washington, D.C. 20590 Special Programs Research and Administration OCT 16 2001 Mr. Michael A. Roby Reference No: 01-0201 Manager-Technical Service Center Rubbermaid Commercial Products 3124 Valley Avenue Winchester, VA 22601 Dear Mr. Roby: This responds to your letter of July 16, 2001, requesting clarification on manufacturing packagings for regulated medical waste (RMW) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that your company manufactures packagings for RMW but you do not provide the inner receptacles. You provide instructions stating: - Only solids may be hauled (no semi-liquids or liquids); - Gross weight may not exceed 27.2 kilograms; - A 3 mil inner liner must be used (top gathered and tied in a single knot); - Must be transported by private or contract motor carrier. Your questions are paraphrased and responded to as follows: Q1. Should any reference and/or restriction be made as to particulars of the "solids" being transported? How close to the type of "mix" tested is the end user required to apply to their "mix" to be hauled? Al. Any mixture of solid materials may be transported in the above described container provided the naximum gross weight as marked on the packaging is not exceeded, however, the packaging may no e used for sharps unless it has been tested as such. For your information, the Food and Drus Administration also has requirements for sharps containers. Q2. May pressure sensitive labels be used for marking a packaging? Is there a performance test that labels need to meet? 010201#

Page 2such labels. A2. Pressure sensitive labels may be used for marking a package. There is no performance test for I hope this information is helpful Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3" ° 01 (MON) 12:20 RUBBERMAID P. 002/002 $173.147 Rubbermaid 3178.3 Commercial Products Marking Packagings 01-0201 Memorandum To: Diane LaValle CC: Patricia Kennedy From: Mike Roby Date: 07/06/01 Ro: Written Interpretation of Regulated Medical Waste Regulations LLC (RCP LLC) requests written clarification/intarpretation for the use of our UN number As a follow-up to our racent telephone conversation, Rubbermaid Commercial Products (RMW). assigned ta our 3517 Combo (base & lid), for the shipment of Ragulated Medical Waste are required by us, to our customar. The "instructions" would state: Since we will not be furnishing the inner packaging, we understand that "instructions" a. Only solids to be hauled (na semi-liquids or liquids), 1. To use ACP's UN number for transporting RMW, the following restrictions apply: c. 3 mil inner liner (tap gathered, twisted and tied in a single knot), b. Gross weight not to exceed 27.2 kilograms, d. Transported by private or contract motor carrier. • "Should any reference and/or restriction be made as to particulars of the "solids" • "How closn to the type of "mix" tested is the and user required to apply to their belng transported?" or, "mix" to hauled?". RCP's "Report" accompanies this memorandum. Pers comply win 4 12a live label used, or making container, they • Request DOT's interpretation of "permanence" requirement, per 178.3 (3), as it ralates to "prassure sansitive" labels. • "Is there a performance test/roquirement that labels need to meet?" RCP thanks you in advance for your assistance in this matter. Aubbermaid Commercial Products LLC 3124 Valley Avanue / Winchester, VA 22601 07/16/01 Phone: 540 667 6700 2062 A Division of Newell Rubbermaid#