{"operation":"document","citation":"02-0299","title":"Air Techniques — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2002-12-12","effective_on":null,"summary":"02-0299 response to Air Techniques concerning 173.134.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0299.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0299.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0299","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020299.pdf","body":"<<<PAGE 1>>>\n\nor sportion\n400 Seventh St., S.W\nResearch and\nWashington, D.C. 20590\nspecial Program:\nAdministratior\nDEC 12 2002\nMs. Elizabeth Paul\nAir Techniques\nRef. No. 02-0299\n70 Cantiague Rock Road\nHicksville, New York 11801\nDear Ms. Paul:\nThis responds to your recent letter concerning requirements for shipping regulated medical waste under\nthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask about\nrequirements related to shipping waste material, including bone and tooth fragments and amalgam and\nsilver filling, generated by dentists' offices.\nYour letter describes a device for transporting dental wastes for processing and disposal. You note\nthat the contents of the device are treated with a disinfectant solution before the device is sealed.\nMedical waste that has been treated or disinfected so as to neutralize or inactivate any infectious\nmaterial is not regulated under the HMR (see § 173.134(b)(8)).\nIf the waste amalgam generated from a dentist's office contains mercury, it may be regulated as a\nhazardous substance under the HMR. A hazardous substance is a material, including its mixtures and\nsolutions, that is listed in Appendix A to § 172.101 and is in a quantity in one package that equals or\nexceeds the reportable quantity (RQ) listed in Appendix A. The RQ for mercury is 1 pound. Thus, if\nyour device contains 1 pound or more of mercury, then it must be transported in accordance with the\nHMR requirements applicable to hazardous substances.\nI hope this information is helpful. If you have further questions, please do not hesitate to contact this\noffice.\nSincerely,\nband 7. Margallo\nEdward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\n173.134\n020299\n40. 240M:\n\n<<<PAGE 2>>>\n\nGorsky\nAIR\nLECHNIDUES\n51.73.197\n70 Cantiague Rock Rd., P.O. Box 870, Hicksville, NY 11801\nCORPORATE HEADQUARTERS\nInfectious Substances\nWESTERN DIVISION\n516/433-7676 Fax 516/433-7683\nOZ5 Brand Line, COstS MeSa DA 92026\n714/435-7930\nFax 714/435-1163\nMr. Edward T. Mazzullo\nDirector of Standards\n400 7th Street\nU.S. DOT Rspa CDHM-10\nSouthwest Washington DC, 20590-0001\nDear Mr Mazzullo:\nDentists use a suction system in order to remove waste while drilling with water to repair\nor replace a tooth. Waste may include bone and tooth fragments as well as amalgam and\nsilver filling that is being replaced.\nsedimentation process, waste particles become trapped on horizontally mounted plates\nWaste particles mixed with water are transported into our device. Utilizing a\ninside the device. A volumetric flow-rate restrictor is incorporated into the device that\nadhere to the plates.\ncontrols the flow of water, thereby allowing enough time for the particles to fall and\nconstructed of stainless steel and the outer case is molded from plastic. The device is\nThere are 67 of these horizontally mounted plates within the device. The plates are\napproximately 16 inches long, by 9 inches wide, by 9 inches tall. The device weighs\napproximately 15 pounds empty, 22 pounds filled with water and can weigh as much as\n24 pounds filled with water and other collected waste particles.\nThe device will be treated with disinfectant solution and sealed prior to removal. For\nshipment to a processor the device is to be placed in a sealed plastic bag, then placed in a\nStyrofoam carton and lastly a cardboard carton.\nRegards,\nElzabich laul\n116-241-551.\nElizabeth Paul","truncated":false,"body_characters":3401}