Pro-Pack Testing Laboratory, Inc. — Hazardous Materials Safety Interpretation

Page 1J.S. Department of Transportatior 400 Seventh Street, S.W. Washington, D.C. 20590 lazardous Materiais Safet ipeline an MAR 8 2005 Administration Mr. Manuel Rosa, Jr. Reference No. 05-0006 2385 Amann Drive President, Pro-Pack Testing Laboratory, Inc. Belleville, IL 62220 Dear Mr. Rosa: This is in further response to your December 22; 2004, letter to Don Burger, General Engineer, Office of Hazardous Materials Technology, requesting clarification on how to properly drop test a bulk wheeled-cart packaging for the transport of "Regulated medical waste, 6.2 (infectious), UN 3291, PG II," under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you stated § 173.197(d)(2)(iii) requires the drop test for non-bulk packagings prescribed in § 178.603, but provides no guidance on how to perform this test on a bulk wheeled cart. Mr. Burger forwarded your letter to this office for response. The reference to § 178.603 in § 173.197(d)(2)(iii) is an error. The correct reference is § 178.810, which prescribes drop test requirements for intermediate bulk containers (IBCs). Because a wheeled cart is similar in size and structure to an IBC, it was our intention to require wheeled carts used for the transportation of regulated medical waste to be capable of meeting the drop test requirements in § 178.810 at the Packing Group II performance level. We will correct this error in a future rulemaking. In the interim, you should utilize the drop test requirements in § 178.810. Note that the standard for wheeled carts is a capability standard. Capability may be or other means. demonstrated using testing, previous handling or transportation experience, design specifications, I hope this information in helpful. Sincerely, Hothe z. Mitchet Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 173.197 050006 178.603#

Page 2Message Page 1 of 1 Drakeford, Carolyn From: Gorsky, Susan Edmonson Sent: Wednesday, January 05, 2005 8:48 AM To: Drakeford, Carolyn 8173.197 Subject: FW: Wheeled Cart for Regulated Medical Waste $178.603 Carolyn, Can you put the email below (with pictures) into the interp system? Thanks. lesting Susan 05-0006 -----Original Message--... Sent: Wednesday, January 05, 2005 8:47 AM From: Burger, Donald Subject: FW: Wheeled Cart for Regulated Medical Waste To: Gorsky, Susan -----Original Message-.-.- Sent: Wednesday, December 22, 2004 3:48 PM From: propack [mailto:propack@mcleodusa.net] Subject: Wheeled Cart for Regulated Medical Waste To: donald.burger@rspa.dot.gov time we discussed this, there were no regulations for wheeled carts in place (see 2001 CFR 49) and so we I once again have an issue with the same wheeled cart that you and I discussed back in 2002. The last in place for wheeled carts but the regulations are not clear enough for me to perform the required tests. In section treated it as a "large" packaging and dropped it once on the bottom at your suggestion. Now there are regulations 173.197(d)(2) (iii), it states that "Each cart must be capable of meeting the requirements of 178.603 (drop test), as cart(s) are to be dropped from 47.2". Section 178.603(a) does not address which type of container a wheeled cart specified for solids at the Packing Group I! performance level." All I can gather from this statement are that the is considered to be which also means I do not know how many carts are to be dropped or in which orientations. Can you help me out here? I have attached pictures of the cart that I have. I appreciate your help Don. Manuel Rosa, Jr. President 618-277-1160 phone Pro-Pack Testing Laboratory, Inc. 618-277-1163 fax www.propacktestlab.com m.rosa@propacktestlab.com 1/10/2005#

Page 3REGULATED MEDICAL WASTE Division 6.2, UN 3291, PG IL 1.H2/Y27.2/S/02/USA/+AA 2638 MEDICAL SYSTEMS NG SAINT LOUIS, MO S3110 En egeney Respocne 314-644-6100#