{"operation":"document","citation":"02-0155","title":"St. John's Health System — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-08-16","effective_on":null,"summary":"02-0155 response to St. John's Health System concerning 173.134.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0155.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0155.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0155","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020155.pdf","body":"<<<PAGE 1>>>\n\n.5. Departmen\n400 Seventh St., S.W.\nf Transportation\nWashington, D.C. 20590\nResearch and\npecial Program\ndministratio\nAUG 16 2002\nMr. Stephen A. Kemp\nReference No. 02-0155\nDirector, Environmental Services\nSt. John's Health System\n1235 East Cherokee\nSpringfield, MO 65804-2263\nDear Mr. Kemp:\nThis is in response to your letter and July 16, 2002 telephone conversation with a member of my\n: \"\nstaff concerning the transportation of \"Regulated medical waste, 6:2, UN 3291, PG II\" under 49\nCFR 173.134(b)(3).\nYour understanding of the exceptions in § 173.134(b)(3) is correct. As provided by\nexcepted froin: (1) the \"INFECTIOUS SUBSTANCE\" label, if the outer packaging is marked\n§ 173.134(b)(3), a regulated medical waste that is transported by a private or contract carrier is\nwith a \"BIOHAZARD\" marking conforming to 29 CFR 1910.1030, and (2) for other than a\nwaste culture or'stock of an infectious substance, the specific packaging requirements in\n§ 173.197, if packaged in a rigid, non-bulk, non-specification packaging conforming to\n§§ 173.24 and 173.24a, and 29 CFR 1910.1030.\nI hope this satisfies your request.\nSincerely\nHothe z. Mither\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n020155\n173.134\n\n<<<PAGE 2>>>\n\nEdmonson\n$173.134\nMERCY\n§ 173:197\nHEALTH SYSTEM\nST. JOHN'S\nRegulated Medical\nUSDOT\nWaste\nRSA\nOffice of Hazardous Materials Standards\n02-0155\n400 7th Street, DHM10 8422\nEdward Mazzullo\nS.W. Washington, D.C., 20590\nMay 16, 2002\nDear Mr. Mazzullo:\nrequirements for Regulated Medical Waste when it is being packaged, handled and transported\nThe purpose of this letter is to confirm my understanding/interpretation. of the packaging\nby a Health System utilizing its own employees and vehicles.\nsurrounding communities that produce small quantities of Regulated Medical Waste. We have a\nSt. Johns Health System is a fully integrated health care network with physician's clinics in the\nsteam sterilizer on the Main Campus of our Health Center that is utilized to sterilize RMW so it\nPhysicians Clinics backito the Health Center for sterilization and disposal using our vehicles and\ncan be appropriately disposed. Currently we are packaging and transporting RMW from the\nemployees.\napplicable to my operation. It is my interpretation that as a private carrierjunder 49 CFR 173.134\nI am seeking clarification of the packaging requirements related to the packaging of RMW\nwe are excepted from the packaging and labeling requirements of 49 CFR 173.197.\nUnder this exception we are required to:\n1. Package in rigid non-bulk packaging that conforms to the general packaging requirements of\n2. The packages must be marked with the \"BIOHAZARD\" marking in accordance with the\n173.24, 173.24a and 29 CFR 1910.1030.\nDepartment of Labor regulations in 29 CFR 1910.1030.\nUnder the exception we are not required to do the following:\n2. Include the specific UN identification number on the packaging label.\n1. Use a package certified at the Packing Group II level.\nPlease advise me at the address below as to the accuracy of my interpretation of the regulations\nas they apply to my situation.\nSincerely,\nSten Athe\nStephen A. Kemp,\nDirector, Environmental Services\n(417) 885-2834\n417-885-2000 ph.\n1235 EAST CHEROKEE • SPRINGFIELD, MISSOURI 65804-2263\nopportunity/affirmative action employer, St. Jahn's does not discriminste against anyone on the basis of race, color, national origin, roligion, age, sex or disability.\nSt. John's Heelth System, a member of the Sisters of Mercy Health System - St. Louis, is a Christian ministry dedicated to healing and wellness. As an equal\n• St. John's facilities are smoke-free environments. Smoking is not permitted on St. John's Health System property.","truncated":false,"body_characters":3754}