St. John's Health System — Hazardous Materials Safety Interpretation

Page 1.5. Departmen 400 Seventh St., S.W. f Transportation Washington, D.C. 20590 Research and pecial Program dministratio AUG 16 2002 Mr. Stephen A. Kemp Reference No. 02-0155 Director, Environmental Services St. John's Health System 1235 East Cherokee Springfield, MO 65804-2263 Dear Mr. Kemp: This is in response to your letter and July 16, 2002 telephone conversation with a member of my : " staff concerning the transportation of "Regulated medical waste, 6:2, UN 3291, PG II" under 49 CFR 173.134(b)(3). Your understanding of the exceptions in § 173.134(b)(3) is correct. As provided by excepted froin: (1) the "INFECTIOUS SUBSTANCE" label, if the outer packaging is marked § 173.134(b)(3), a regulated medical waste that is transported by a private or contract carrier is with a "BIOHAZARD" marking conforming to 29 CFR 1910.1030, and (2) for other than a waste culture or'stock of an infectious substance, the specific packaging requirements in § 173.197, if packaged in a rigid, non-bulk, non-specification packaging conforming to §§ 173.24 and 173.24a, and 29 CFR 1910.1030. I hope this satisfies your request. Sincerely Hothe z. Mither Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 020155 173.134#

Page 2Edmonson $173.134 MERCY § 173:197 HEALTH SYSTEM ST. JOHN'S Regulated Medical USDOT Waste RSA Office of Hazardous Materials Standards 02-0155 400 7th Street, DHM10 8422 Edward Mazzullo S.W. Washington, D.C., 20590 May 16, 2002 Dear Mr. Mazzullo: requirements for Regulated Medical Waste when it is being packaged, handled and transported The purpose of this letter is to confirm my understanding/interpretation. of the packaging by a Health System utilizing its own employees and vehicles. surrounding communities that produce small quantities of Regulated Medical Waste. We have a St. Johns Health System is a fully integrated health care network with physician's clinics in the steam sterilizer on the Main Campus of our Health Center that is utilized to sterilize RMW so it Physicians Clinics backito the Health Center for sterilization and disposal using our vehicles and can be appropriately disposed. Currently we are packaging and transporting RMW from the employees. applicable to my operation. It is my interpretation that as a private carrierjunder 49 CFR 173.134 I am seeking clarification of the packaging requirements related to the packaging of RMW we are excepted from the packaging and labeling requirements of 49 CFR 173.197. Under this exception we are required to: 1. Package in rigid non-bulk packaging that conforms to the general packaging requirements of 2. The packages must be marked with the "BIOHAZARD" marking in accordance with the 173.24, 173.24a and 29 CFR 1910.1030. Department of Labor regulations in 29 CFR 1910.1030. Under the exception we are not required to do the following: 2. Include the specific UN identification number on the packaging label. 1. Use a package certified at the Packing Group II level. Please advise me at the address below as to the accuracy of my interpretation of the regulations as they apply to my situation. Sincerely, Sten Athe Stephen A. Kemp, Director, Environmental Services (417) 885-2834 417-885-2000 ph. 1235 EAST CHEROKEE • SPRINGFIELD, MISSOURI 65804-2263 opportunity/affirmative action employer, St. Jahn's does not discriminste against anyone on the basis of race, color, national origin, roligion, age, sex or disability. St. 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 • St. John's facilities are smoke-free environments. Smoking is not permitted on St. John's Health System property.#