Air Techniques — Hazardous Materials Safety Interpretation

Page 1or sportion 400 Seventh St., S.W Research and Washington, D.C. 20590 special Program: Administratior DEC 12 2002 Ms. Elizabeth Paul Air Techniques Ref. No. 02-0299 70 Cantiague Rock Road Hicksville, New York 11801 Dear Ms. Paul: This responds to your recent letter concerning requirements for shipping regulated medical waste under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about requirements related to shipping waste material, including bone and tooth fragments and amalgam and silver filling, generated by dentists' offices. Your letter describes a device for transporting dental wastes for processing and disposal. You note that the contents of the device are treated with a disinfectant solution before the device is sealed. Medical waste that has been treated or disinfected so as to neutralize or inactivate any infectious material is not regulated under the HMR (see § 173.134(b)(8)). If the waste amalgam generated from a dentist's office contains mercury, it may be regulated as a hazardous substance under the HMR. A hazardous substance is a material, including its mixtures and solutions, that is listed in Appendix A to § 172.101 and is in a quantity in one package that equals or exceeds the reportable quantity (RQ) listed in Appendix A. The RQ for mercury is 1 pound. Thus, if your device contains 1 pound or more of mercury, then it must be transported in accordance with the HMR requirements applicable to hazardous substances. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, band 7. Margallo Edward T. Mazzullo Director, Office of Hazardous Materials Standards 173.134 020299 40. 240M:#

Page 2Gorsky AIR LECHNIDUES 51.73.197 70 Cantiague Rock Rd., P.O. Box 870, Hicksville, NY 11801 CORPORATE HEADQUARTERS Infectious Substances WESTERN DIVISION 516/433-7676 Fax 516/433-7683 OZ5 Brand Line, COstS MeSa DA 92026 714/435-7930 Fax 714/435-1163 Mr. Edward T. Mazzullo Director of Standards 400 7th Street U.S. DOT Rspa CDHM-10 Southwest Washington DC, 20590-0001 Dear Mr Mazzullo: Dentists use a suction system in order to remove waste while drilling with water to repair or replace a tooth. Waste may include bone and tooth fragments as well as amalgam and silver filling that is being replaced. sedimentation process, waste particles become trapped on horizontally mounted plates Waste particles mixed with water are transported into our device. Utilizing a inside the device. A volumetric flow-rate restrictor is incorporated into the device that adhere to the plates. controls the flow of water, thereby allowing enough time for the particles to fall and constructed of stainless steel and the outer case is molded from plastic. The device is There are 67 of these horizontally mounted plates within the device. The plates are approximately 16 inches long, by 9 inches wide, by 9 inches tall. The device weighs approximately 15 pounds empty, 22 pounds filled with water and can weigh as much as 24 pounds filled with water and other collected waste particles. The device will be treated with disinfectant solution and sealed prior to removal. For shipment to a processor the device is to be placed in a sealed plastic bag, then placed in a Styrofoam carton and lastly a cardboard carton. Regards, Elzabich laul 116-241-551. Elizabeth Paul#