Medical Waste Solutions, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety JUN 1 5 2006 Mr. Russell A. Karlins Reference No. 06-0007 P.O. Box 64787 Medical Waste Solutions, Inc. Gary, IN 46401 Dear Mr. Karlins: This is in response to your e-mail to Ms. Susan Gorsky, Regulations Officer, Office of Hazardous Materials Standards, and e-mail to a member of my staff asking if re-useable polyethylene drums must be lined with a polyethylene liner before they can contain sharps under the Hazardous Materials Regulations (49 CFR Parts 171-180). We apologize for the containers filled with "Regulated medical waste, n.o.s., 6.2 (infectious), UN 3291, PG II" delay in responding an any inconvenience this may have caused. hazard classes it contains, the answer is no. If the use of a plastic liner is necessary to that Provided the packaging meets the applicable performance criteria under the HMR for the packaging's performance, such as to satisfy the moisture or leak resistance criteria under § 173.134 or § 173.197, the liner must be used. I hope this satisfies your request. Sincerely, Hatle s Mtehile Hattie L. Mitchell, Chief Office of Hazardous Materials Standards Regulatory Review and Reinvention 173.134 173.197 060007#

Page 2Page 1 of 1 Drakeford, Carolyn <PHMSA> From: Gorsky, Susan <PHMSA> Edmonson Sent: Wednesday, January 04, 2006 2:45 PM To: Drakeford, Carolyn <PHMSA> §173.197 Subject: FW: sharps containers §173.134. Could you make this an interp please for a written response to Mr. Karlins? Thanks. Regulated Medical Waste 86. 0007 From: Russell Karlins [mailto:russ@medicalwastesolutions.com] Sent: Monday, December 19, 2005 5:09 PM Cc: 'Mark Charles'; 'Jim Wiltjer' To: Gorsky, Susan <PHMSA> Subject: sharps containers Susan, Hope this email finds you dong well. If you recall last week we spoke of the hospital that was written up because shipping them off site. The hospital uses us as a commercial hauler and the sharps containers are placed inside they were not placing a liner in the reusable plastic drum that contained their disposable sharos containers prior to of a reusable plastic drum for shipment. In the past you have answered with emails and on the phone by saying no. The hospital simply wants something The question is do they need to place a liner in a plastic drum that contains sharps containers prior to shipment? more current to attach with their response from the inspection. Have a great day and thank you very much for your help. Medical Waste Solutions, Inc.800-451-6244 Russell A. Karlins 312-804-3701 Cell Phone Chemical Disposal Services, Inc. 877-978-7918 www.medicalwastesolutions.com 1/4/2006#