Information From Science, LLC — Hazardous Materials Safety Interpretation

Page 1of Transportation J.S. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 A ministration se #49 21 2003 Information From Science, LLC Mr. Ira F. Salkin, Ph.D., F(AAM) Ref. No. 02-0270 P.O. Box 408 West Sand Lake, NY. 12196 Dear Mr. Salkin: contained in suction canisters in accordance with revisions to the Hazardous Materials Regulations This responds to your October 15, 2002 letter requesting clarification on processing waste body fluids (HMR; 49 CFR Parts 171-180) under Final Rule, Docket HM-226. Your questions are paraphrased and answered as follows: Q1. When suction canisters containing three liters or more of waste body fluids are transported for off- site treatment and disposal in non-bulk containers, should they be packed as described in § 173.197, i.e., in packaging that meets DOT's Packing Group II performance standards? A1. Waste body fluids may be packaged according to provisions in §173.197(b) or under exceptions provided in §173.134(c) or §173.6. Xou are correct that § 173.197 requires non-bulk packagings for regulated medical waste (RMW) to be UN specification packaging conforming to Packing Group I performance requirements in Part 178 of the HMR. However, § 173.134(c) permits RMW that is transported in dedicated vehicles by private or contract carriers to be packaged in non-specification non-bulk packagings, provided such packagings are rigid and conform to the general packaging requirements in §$ 173.24 and 173.24a of the HMR and Occupational Safety and Health Administration (OSHA) regulations in 29 CFR 1910.1030. In addition, the materials of trade (MOTS) exception in § 173.6 permits RMW to be transported by a private motor carrier in non-specification combination packagings. For liquid RMW, the inner packagings must be leak-tight and the outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packagings. The outer packaging must be a strong, tight packaging that is securely closed. The MOTS exception includes limits on the capacity of a packaging. Q2. Since I am not aware of any commercially available suction canisters that would meet Packing Group II specifications, would the canisters have to be packaged in Packing Group II type of packaging when transported in bulk containers? A2. Liquid RMW transported in a bulk packaging, i.e., a large packaging, wheeled cart, or bulk outer packaging, must be packaged in a rigid inner packaging that conforms to the general packaging 191 113 020270 341D228 2200A#

Page 2requirements of Part 173 of the HMR, specifically the general packaging requirements in $§ 173.24 and 173.24a. Such inner packagings need not be UN specification packagings, nor are there performance requirements for the inner packagings. 03. Relative to Packing Group II standards, wouldn't the canisters with the waste body fluids have to be placed into plastic bags with sufficient absorbent materials to absorb and retain all liquids during transportation? A3. There is no requirement for inner packagings of liquid RMW that are transported inside bulk containers to be placed in plastic bags with absorbent material. Q4. Do cardboard boxes meet the DOT standards for rigid outer containers or must these containers be composed of more durable materials, e.g., fiberboard? packaging means a packaging that is not flexible, will retain its shape, and will not yield to knocks, A4. We have not formally defined the term "rigid" in the HMR. Generally, the requirement for a rigid bumps, drops, or other forces that may be encountered during transportation. I hope this answers your inquiry. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 3Oct 15 02 07:222 Ira 518-674-1713 p. 2 Boothe §173.197 Hazardous Waste IfS • INFORMATION FROM SCIENCE, LLC 02-0270 P.O BOX 408 WEST SAND LAKE, NY 12196 October 15, 2002 Mr. Edward T. Mazzullo DHM-10 Office of Hazardous Materials Standards United State Department of Transportation 400 7th Street, SW Washington, DC 20510 Dear Mr. Mazzullo: the New York Sate Regulated Medical Waste Program. Having retired from state You may recall that we met at several conferences when I was the Director of service, I have entered the world of private consulting in the area of waste formal interpretations of components of the Department of Transportation's (DOT) rule management. In this regard, I have been requested by one of my clients to obtain under HM-226, Hazardous Materials: Revision to Standards for Infectious Substances. My questions focus on the processing of waste body fluids contained in suction canisters. In discussing my views on this subject with Ms. Sue Gorsky, she suggested that I direct my inquires to you for formal responses. Specifically, I would appreciate receiving DOT's answers to the following questions: 1. When suction canisters containing upwards of three liters of waste body fluids are transported for off-site treatment and disposal in non-bulk containers, should they not be packed as described in §173.197, i.e., in Have I correctly interpreted this subsection of the rule? packaging that meets DOT's Packing Group I! performance standards? that would meet Packing Group Il specifications, would not the canisters 2. Since I am not award of any commercially available suction canisters uk containers? Have I correctly interoreted this component of $173.19 lave to be packaged in Group Il type of packaging when transported it#

Page 4. Oct.15 02 07:22a Ira 518-674-1713 p. 3 the waste body fluids have to be placed into plastic bags with sufficient 3. Relative to Packing Group II standards, wouldn't't the canisters with absorbent materials to absorb and retain all liquids during transportation? In addition, may I infer that the absorbent material cannot be discarded surgical gowns, drapes or similar waste fabrics?; and 4. Do cardboard boxes meet the DOT standards for rigid outer containers or must these containers be composed of more durable materials, e.g., fiberboard? Thank you in advance for your interpretations of these questions and | look forward to receiving your responses in the near future. If you have need of any additional information from me, please don't hesitate to contact me at 518-674-1713 (voice/fax) or at irasalkin@aol.com (e-mail). Sincerely, Information From Science, LLC Ira F. Salkin, Ph.D., F(AAM) 2.#