Toppenish Community Hospital — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E Washington, D.C. 20590 Carolyn Arms, MT(ASCP) Director of Laboratory Yakima Regional Medical & Cardiac Center Toppenish Community Hospital 3.10 South 9l" Avenue Yakiina, WA 98902 Reference No. 08-0158 Dear Ms. Arms: This is in response to your e-mail requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of infectious substances. Specifically, you ask if a Petri dish containing a Category B infectious substance and covered with a lid that is not leak- or sift-proof meets the definition of a primary receptacle (packaging) under § 173.199 of the HMR. You also ask if the packaging would be considered leak- or sift-proof if it is placed inside another contaiiler that does meet this requirement, such as a sealed polyethylene bag. We apologize for the delay in responding and any inconvenience this inay have caused. A Petri dish covered with a lid that is not leak- or sift-proof does not meet the definition of a primary receptacle under § 173.199 of the HMR. The HMR require primary receptacles for Category B infectious substances to be leak-proof for liquids and sift-proof for solids. Often these types of closure can be achieved by securely attaching a lid to a packaging with wire, tape, or ally other positive means, such as a friction closure. See 5 173.199(b)(l) and (c)(l). Alternatively, to meet this requirement, a petri dish may be placed in a secoild container, such as a sealed polyethylene bag, that is leak-proof if the dish contains liquids and sift-proof if it contains solids. In this case, the polyethylene bag is the primary receptacle for purposes of the triple packaging requirelneilt in 5 173.199. It is the opinion of this Office that placing the Petri dish within the polyethylene bag in a maniler that secures the lid to the dish while the packaging is in transportation may facilitate the successful performance of this packaging. Primary receptacles must be packed in a secondary packaging in a manner that ensures the primary receptacles cannot break, be punctured, or leak their contents under normal transportation conditions. The secoildary packaging must be secured in a rigid outer packaging with cushioning material that must not become impaired or impair the performance of the outer packaging if exposure to the packaging's conteiits occurs. Further, the con~pleted#

Page 2package must be designed, constructed, maintained, filled, its contents limited, and each container in the packaging closed so that under normal transportation conditions the completed package will not permit any release of hazardous material into the environment. See 9 173.199(a)(2), (a)(3), and (a)(4). I hope this satisfies your request. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3Shipping of petri dishes Drakeford, Carolyn <PHMSA> From: Edmonson, Eileen <PHMSA> Sent: Tuesday, June 03,2008 7:02 AM To: Drakeford, Carolyn <PHMSA> Cc: Mitchell, Hattie <PHMSA>; INFOCNTR <PHMSA> Subject: FW: Shipping of petri dishes From: Arms, Carolyn [mailto:Carolyn.Arms@yakima.hma-corp.com] Sent: Friday, May 30, 2008 1:30 PM To: INFOCNTR <PHMSA> Cc: Gicca, Ron Subject: Shipping of petri dishes To: US Dept of Transportation AlTN: Eileen Edmundson - DOT - (202) 366-8553 My name is Carolyn Arms and I am the Laboratory Director of a small rural hospital in Washington State. This email is in response to a phone conversation between myself and Eileen Admundson of the DOT on Wednesday May 28, 2008. 1 called Eileen for a clarification of the regulations regarding shipment of Category B infectious substances; specifically shipping inoculated culture media on petri dishes. Our laboratory currently plates microbiology cultures onto petri dishes and incubates the cultures until transport to a larger hospital in our area. We have been placing the petri dishes into sealed bags, then placing the bags into a secondary and tertiary container as directed in the regulations. The Washington State Department of Health released an article in their publication "Elaborations" in NovIDec 2007 stating that the petri dish must be considered as the "primary" container and is therefore unsuitable for shipment. At our small hospital, if we cannot plate our cultures and incubate until transport, we will add up to 24 hours delay in diagnostic test results. This will significantly affect our patient care. We are asking for a clarification in regard to what may be considered the primary container. Must we consider the petri dish as the "primary container" or is it acceptable to meet the intent of the regulation by placing the dishes into another container that is leaklsift proof? Thank you for your time and consideration. Carolyn Arms MT(ASCP) Director of Laboratory Yakima Regional Medical & Cardiac Center Toppenish Community Hospital 110 So. 9th Ave. Yakima, WA 98902 502 W. 4th Ave. Toppenish, WA. 98948 (509)575-5132 or (509)865-1512 Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.#