{"operation":"document","citation":"10-0179","title":"Washington State Public Health Laboratories — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-12-17","effective_on":null,"summary":"10-0179 response to Washington State Public Health Laboratories concerning 173.196, 178.609.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0179.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0179.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0179","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100179.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Ave, SE\nWashington, D.C. 20590\nPipeline and Hazardous Materials\nSafety Administration\nDEC 1 7 20lu\nMr. Chuck Talburt\nLaboratory Program Advisor\nWashington State Public Health Laboratories\n1610 NE 150th Street\nShoreline, WA 98155\nReference No. 10-0179\nDear Mr. Talburt:\nThis is in response to your e-mail to the Pipeline and Hazardous Materials Safety\nAdministration's (PHMSA's) Hazardous Materials Information Center, and subsequent\ntelephone conversation with a member of my staff. In your letter, you state most of the petri\ndishes your clients use are made from plastic and they would like to use these dishes to transport\nanthrax cultures, which are typically Division 6.2 (infectious) Category A materials. You ask if\npetri dishes with lids may be used as primary containers to transport these cultures by motor\nvehicle, railcar, or aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171180).\nUnder § 173.196, a packaging for a Division 6.2 material that is a Category A infectious\nsubstance must meet the performance test requirements prescribed in § 178.609 and be marked\nin conformance with § 178.503(f). A packaging for a Category A infectious substance is a triple\npackaging consisting of a leakproof primary receptacle, a leakproof secondary packaging, and\nrigid outer packaging of adequate strength for its capacity, mass, and intended use (see\n§ 173.196(a)(3)). Provided the completed package meets the applicable design requirements\nprescribed in § 173.196 for an infectious substance packaging, and the package successfully\npasses the performance tests required in § 178.609, use of the petri dish as an inner packaging to\ntransport Category A anthrax cultures would be acceptable. However, a petri dish's lid is\ntypically not designed to be watertight. Therefore, additional packaging materials may be\nneeded to meet this condition. For example, the lid of the dish could be secured to its base with\ntape or parafilm and this packaging placed in a sealed polyethylene bag that is watertight. This\nprimary packaging could then be placed in a secondary packaging and secured in a manner that\n\n<<<PAGE 2>>>\n\nprevents any puncture, tear, or breakage of the packaging materials. Further, the performance\ntests in § 178.609 require the packaging to be dropped on its bottom, top, sides, and corner, and\ncold-conditioned and immersed in water with no leakage from the primary receptacle.\nAdditional requirements in §§ 173.196 and 178.609 may also apply.\nI hope this satisfies your request.\nSincerely,\n~~~--\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n2\n\n<<<PAGE 3>>>\n\nt...avnon~Yl\n§ 17 3-Jq~\n§ 173 ./qqDrakeford. Carolyn (PHMSA)\nFrom: INFOCNTR (PHMSA) -:t=rtf'ofchoLls Substances\nSent: Wednesday, August 11, 2010 10:34 AM\nTo: Drakeford, Carolyn (PHMSA) 10- 0111\nSubject: FW: Shipping Category A infectious substances\nFrom: Talburt, Chuck D (DOH) [mailto:Chuck.Talburt@DOH.WA.GOV]\nSent: Tuesday, August 10, 2010 5:32 PM\nTo: INFOCNTR (PHMSA)\nSubject: Shipping Category A infectious substances\nTo Whom It May Concern,\nThis is a follow up from a previous email on this subject.\nI am interested in knowing specifically whether Category A, infectious substances, can be shipped by either\nground or air using Petri dishes as primary containers. References 08-0276 and 08-0158 clarify the use of Petri\ndishes as primary containers for Category B cultures. However, I am concerned that laboratories in our state\nmay be sending in Category A, infectious substances, using Petri dishes as primary containers. We are\nconcerned particularly regarding possible anthrax cultures.\nCould you please forward an interpretation regarding this question?\nThank you for your assistance in this matter.\nPlease address your response to:\nChuck Talburt\nWashington State Public Health Laboratories\n1610 N E 150th Street\nShoreline, Washington 98155\nChuck Talburt\nLaboratory Program Advisor\nphone: (206) 418-5404\nemail address: ChuckTalburt@doh.wa.gov\n\"The Department of Health Works to Protect and Improve the Health of People in Washington State\"\n1","truncated":false,"body_characters":4166}