# Air Techniques — Hazardous Materials Safety Interpretation

- **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:** Not available
- **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>>>

or 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 2>>>

Gorsky
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
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