Henderson and Walton Women"s Center, P.C. — Hazardous Materials Safety Interpretation

Page 1....... of Transportatior J.S. Department 400 Seventh St., Ş.W. Research and Washington, D.C. 20590 Administration Speciat Programs APR 2 2 2003 Ms. Jane Smith Henderson and Walton Women's Center, 806 St. Vincent's Drive, Suite 500 P.C. Ref. No. 03-0064 Birmingham, AL 35205 Dear Ms. Smith: This is in response to your letter dated February 25, 2003, requesting clarification of the Hazardous Materials (HMR; 49 CFR Parts 171-180). information on who is considered a offeror of hazardous material Specifically, you requested and thus 172, Subpart H. subject to the DOT hazmat training requirements in Part following: selection of the packaging for a hazardous material, Functions of an offeror include, but are not limited to the classifying hazardous materials, preparing shipping papers, physical transfer of hazardous materials to a carrier, international equivalents, signing hazardous material reviewing shipping paper to verify compliance with the HMR or markings or placards on vehicles or packages, and providing certifications on shipping papers, placing hazardous materials offeror functions, placards to a carrier. such as the closing of packages, is a hazmat Therefore, a company that performs employer and is subject to $ 172.704. I hope this satisfies your request. Sincerely. Office of Hazardous Materials Standards 030064 172.704 . si#

Page 2HENDERSON&WALTON Ronald E. Henderson, M.D. WOMEN'S CENTER, PC Philip D. Walton, M.D. 3|12.104 Founders Frank O. Page, M.D. framing John R. Faucette, M.D. • Jeffrey Gunnells, M.D. Charles Hudson, M.D Carol G. Swindle, M.D. 03-6144 Brenda C. Taylor, M.D. Cynthia L. Lassiter. M.D A. Elizabeth Snowden, M.D. 2/25/2003 Cynthia L. Jones, M.D. John L. Edwards, M.D Edward Mazullo Marian L. McCord, M.D Ernest G. Moore, M.D George H. McGrady, M.D Dan H. Hudson, M.D. Charles H. Svensson, M.D. Washington, DC 20590 Lauren B. Britt, M.D. Alison A. Heaton, M.D. Dear Sir, regulations to workers in healthcare facilities. I have a question regarding the applicability to the US DOT hazardous materials Question: We are a private OB/GYN physician office. We contract out to Stericycle to containers, red bags, and labels and handles the paperwork to meet DOT requirements. pick-up and transport our hazardous waste. Stericycle provides us with the DOT Our associates put the boxes together, handle the red bags, and close the containers to ready them for Stericycle to pick up. We provide annual OSHA/SAFETY training for our associates which covers the handling of hazardous waste. My question is, are we considered an "offeroi" in this situation and subject to the training requirements? I received an letter of interpretation from your offiet, which I have shared with my ur associates are to has bread in ties training outed are his ran SHA representative. T nedical facilities. I have vet to find anyone that is doing this for their staf o validate with someone that this training is actually required. From talking with othe Thank you for your time and assistance, wlat letter Jina sinath Tina Smith Henderson and Walton Women's Center St. Vincent's Women's & Children's Cente 306 St. Vincent's Drive, Suite 500 44 2nd Street, N.V 12051 930-1800 FAX 1205 90-1818 Suite 10 1009 7th Avenue Alabaster. 062003 35007 Jasper, Alabama 35501 (205) 221-4221 525 Leighton Avenue Anniston, Alabama 36201 Suite A 9 South Western Avenue lacauga, Alabama 351 Ill 4th Avenue N.E. (256) 236-7541 56) 249-40 Cullman, Alabama 35055 5 Church Stre (256) 737-9306 Rainbow City, Alabama 35906 jite (256) 442-7740#