{"operation":"document","citation":"02-0270","title":"Information From Science, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-03-21","effective_on":null,"summary":"02-0270 response to Information From Science, LLC concerning 173.197.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0270.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0270.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0270","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020270.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nJ.S. Department\n400 Seventh St., S.W.\nResearch and\nWashington, D.C. 20590\nA ministration se\n#49 21 2003\nInformation From Science, LLC\nMr. Ira F. Salkin, Ph.D., F(AAM)\nRef. No. 02-0270\nP.O. Box 408\nWest Sand Lake, NY. 12196\nDear Mr. Salkin:\ncontained in suction canisters in accordance with revisions to the Hazardous Materials Regulations\nThis responds to your October 15, 2002 letter requesting clarification on processing waste body fluids\n(HMR; 49 CFR Parts 171-180) under Final Rule, Docket HM-226. Your questions are paraphrased\nand answered as follows:\nQ1. When suction canisters containing three liters or more of waste body fluids are transported for off-\nsite treatment and disposal in non-bulk containers, should they be packed as described in § 173.197,\ni.e., in packaging that meets DOT's Packing Group II performance standards?\nA1. Waste body fluids may be packaged according to provisions in §173.197(b) or under exceptions\nprovided in §173.134(c) or §173.6. Xou are correct that § 173.197 requires non-bulk packagings for\nregulated medical waste (RMW) to be UN specification packaging conforming to Packing Group I\nperformance requirements in Part 178 of the HMR. However, § 173.134(c) permits RMW that is\ntransported in dedicated vehicles by private or contract carriers to be packaged in non-specification\nnon-bulk packagings, provided such packagings are rigid and conform to the general packaging\nrequirements in §$ 173.24 and 173.24a of the HMR and Occupational Safety and Health\nAdministration (OSHA) regulations in 29 CFR 1910.1030. In addition, the materials of trade (MOTS)\nexception in § 173.6 permits RMW to be transported by a private motor carrier in non-specification\ncombination packagings. For liquid RMW, the inner packagings must be leak-tight and the outer\npackaging must contain sufficient absorbent material to absorb the entire contents of the inner\npackagings. The outer packaging must be a strong, tight packaging that is securely closed. The MOTS\nexception includes limits on the capacity of a packaging.\nQ2. Since I am not aware of any commercially available suction canisters that would meet Packing\nGroup II specifications, would the canisters have to be packaged in Packing Group II type of\npackaging when transported in bulk containers?\nA2. Liquid RMW transported in a bulk packaging, i.e., a large packaging, wheeled cart, or bulk outer\npackaging, must be packaged in a rigid inner packaging that conforms to the general packaging\n191\n113\n020270\n341D228\n2200A\n\n<<<PAGE 2>>>\n\nrequirements of Part 173 of the HMR, specifically the general packaging requirements in $§ 173.24\nand 173.24a. Such inner packagings need not be UN specification packagings, nor are there\nperformance requirements for the inner packagings.\n03. Relative to Packing Group II standards, wouldn't the canisters with the waste body fluids have to\nbe placed into plastic bags with sufficient absorbent materials to absorb and retain all liquids during\ntransportation?\nA3. There is no requirement for inner packagings of liquid RMW that are transported inside bulk\ncontainers to be placed in plastic bags with absorbent material.\nQ4. Do cardboard boxes meet the DOT standards for rigid outer containers or must these containers\nbe composed of more durable materials, e.g., fiberboard?\npackaging means a packaging that is not flexible, will retain its shape, and will not yield to knocks,\nA4. We have not formally defined the term \"rigid\" in the HMR. Generally, the requirement for a rigid\nbumps, drops, or other forces that may be encountered during transportation.\nI hope this answers your inquiry.\nSincerely,\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nOct 15 02 07:222\nIra\n518-674-1713\np. 2\nBoothe\n§173.197\nHazardous Waste\nIfS\n• INFORMATION FROM SCIENCE, LLC\n02-0270\nP.O BOX 408\nWEST SAND LAKE, NY 12196\nOctober 15, 2002\nMr. Edward T. Mazzullo\nDHM-10\nOffice of Hazardous Materials Standards\nUnited State Department of Transportation\n400 7th Street, SW\nWashington, DC 20510\nDear Mr. Mazzullo:\nthe New York Sate Regulated Medical Waste Program. Having retired from state\nYou may recall that we met at several conferences when I was the Director of\nservice, I have entered the world of private consulting in the area of waste\nformal interpretations of components of the Department of Transportation's (DOT) rule\nmanagement. In this regard, I have been requested by one of my clients to obtain\nunder HM-226, Hazardous Materials: Revision to Standards for Infectious Substances.\nMy questions focus on the processing of waste body fluids contained in suction\ncanisters. In discussing my views on this subject with Ms. Sue Gorsky, she suggested\nthat I direct my inquires to you for formal responses. Specifically, I would appreciate\nreceiving DOT's answers to the following questions:\n1. When suction canisters containing upwards of three liters of waste\nbody fluids are transported for off-site treatment and disposal in non-bulk\ncontainers, should they not be packed as described in §173.197, i.e., in\nHave I correctly interpreted this subsection of the rule?\npackaging that meets DOT's Packing Group I! performance standards?\nthat would meet Packing Group Il specifications, would not the canisters\n2. Since I am not award of any commercially available suction canisters\nuk containers? Have I correctly interoreted this component of $173.19\nlave to be packaged in Group Il type of packaging when transported it\n\n<<<PAGE 4>>>\n\n. Oct.15\n02 07:22a\nIra\n518-674-1713\np. 3\nthe waste body fluids have to be placed into plastic bags with sufficient\n3. Relative to Packing Group II standards, wouldn't't the canisters with\nabsorbent materials to absorb and retain all liquids during transportation?\nIn addition, may I infer that the absorbent material cannot be discarded\nsurgical gowns, drapes or similar waste fabrics?; and\n4. Do cardboard boxes meet the DOT standards for rigid outer containers\nor must these containers be composed of more durable materials, e.g.,\nfiberboard?\nThank you in advance for your interpretations of these questions and | look\nforward to receiving your responses in the near future. If you have need of any\nadditional information from me, please don't hesitate to contact me at 518-674-1713\n(voice/fax) or at irasalkin@aol.com (e-mail).\nSincerely,\nInformation From Science, LLC\nIra F. Salkin, Ph.D., F(AAM)\n2.","truncated":false,"body_characters":6432}