{"operation":"document","citation":"06-0229","title":"National Headquarters — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-10-26","effective_on":null,"summary":"06-0229 response to National Headquarters concerning 173.197, 173.6.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0229.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0229.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0229","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060229.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nNashington, D.C. 20591\n100 Seventh Street, S.W\nHazardous Materials Safety\nPipeline and\nOCT 26 2006\nAdministration\nMr. Michael I. Gorman\nRef. No.: 06-0229\nNE 7041B\nSenior Consultant\n2025 E Street, NW\nNational Headquarters\nWashington, DC 20006\nDear Mr. Gorman:\nThis is in response to your October 10, 2006 letter requesting clarification of the training\n180). Specifically, you ask if there were any changes to the training requirements for\nrequirements provided in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-\nregulated medical waste shipments prepared in accordance with § 173.197 or § 173.6 of\nthe HMR as a result of the recent rulemaking on infectious substances.\nOn June 2, 2006 we published a final rule under Docket HM-226A entitled \"Hazardous\nMaterials: Infectious Substances; Harmonization with the United Nations\nRecommendations,\" which became effective on October 1, 2006. The rulemaking revised\nthe transportation requirements for infectious substances, including regulated medical\ncommunication requirements consistent with revised international standards and to clarify\nwaste, to adopt new classification criteria, new exceptions, and packaging and hazard\nexisting requirements to promote compliance.\nDocket HM-226A did not alter the training requirements applicable to the transportation of\nregulated medical waste. Materials transported under § 173.197 continue to be subject to\nthe training requirements in Part 172, Subpart H of the HMR. When regulated medical\nwaste is transported as a Materials of Trade Exception in accordance with § 173.5, the\noperator of the motor vehicle must be informed of the presence of the hazardous material\nand be informed on the requirements in § 173.6, but is not subject the training\nrequirements in Part 172, Subpart H of the HMR.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely\nOffice of Hazardous Materials Standards\n113.197 (e)\n173.6\n060229\n\n<<<PAGE 2>>>\n\nPage 1 of 2\nSupko\n$173.197 (eS\nINFOCNTR <PHMSA>\n§173.6\nFrom: Gorman@usa.redcross.org\ntraining\nSent: Monday, October 09, 2006 4:59 PM\n08-0229\nTo:\nINFOCNTR <PHMSA>\nCc:\nBLloyd@usa.redcross.org; EavesS@usa.redcross.org; DCozart@usa.redcross.org;\nHavasS@usa.redcross.org; ChandlerJe@usa.redcross.org\nSubject: Regulated Medical Waste, N.O.S.: Offeror and Transporter Training Requirements\nMr. Edward T. Mazzullo\nU.S. DOT/PHMSA (PHH-10)\nDirector, Office of Hazardous Materials Standards\nWashington, D.C. 20590-0001\n400 7th Street S. W.\nDear Mr. Mazzullo,\nmedical waste, n.o.s. as stated in the June 2, 2006 Federal Register which went into effect on October 1,\nThis email concerns the new DOT training requirements for offerors and transporters of Regulated\n2006. First let me say that the only type of Regulated Medical Waste generated by American Red\nCross facilities is Category B.\nIn two separate phone calls to the Hazardous Materials Information Center, DOT staff indicated that\nTrial and reen general dees Seen y Agrees made Waitican Puntin peci\ninitial and recurrent General Awareness,\nsubstances). They based their guidance on the following verbiage from the new regulations:\n(e) Training. Each person who offers\n49 CFR § 173.199 Category B infectious substances.\nor transports a Category B infectious\nsubstance under the provisions of this\nsection must know about the\nrequirements of this section.\nWhile I do not disagree with their interpretation, I would like written confirmation from rederal DOT\nthat the above training is no longer required\nsubstances transported under 49 CFR Part 173.6 as a Material of Trade?\nI have one additional question. Does the new training requirement apply to Category B infectious\nThe personal contact information you require on your website for information requests is provided\nbelow.\nThanks\nMike Gorman\n+ American Red Cross\nEnterprise Risk\nCorporate Safety Office\n10/10/2006","truncated":false,"body_characters":3938}