Washington State Public Health Laboratories — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Ave, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration DEC 1 7 20lu Mr. Chuck Talburt Laboratory Program Advisor Washington State Public Health Laboratories 1610 NE 150th Street Shoreline, WA 98155 Reference No. 10-0179 Dear Mr. Talburt: This is in response to your e-mail to the Pipeline and Hazardous Materials Safety Administration's (PHMSA's) Hazardous Materials Information Center, and subsequent telephone conversation with a member of my staff. In your letter, you state most of the petri dishes your clients use are made from plastic and they would like to use these dishes to transport anthrax cultures, which are typically Division 6.2 (infectious) Category A materials. You ask if petri dishes with lids may be used as primary containers to transport these cultures by motor vehicle, railcar, or aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171180). Under § 173.196, a packaging for a Division 6.2 material that is a Category A infectious substance must meet the performance test requirements prescribed in § 178.609 and be marked in conformance with § 178.503(f). A packaging for a Category A infectious substance is a triple packaging consisting of a leakproof primary receptacle, a leakproof secondary packaging, and rigid outer packaging of adequate strength for its capacity, mass, and intended use (see § 173.196(a)(3)). Provided the completed package meets the applicable design requirements prescribed in § 173.196 for an infectious substance packaging, and the package successfully passes the performance tests required in § 178.609, use of the petri dish as an inner packaging to transport Category A anthrax cultures would be acceptable. However, a petri dish's lid is typically not designed to be watertight. Therefore, additional packaging materials may be needed to meet this condition. For example, the lid of the dish could be secured to its base with tape or parafilm and this packaging placed in a sealed polyethylene bag that is watertight. This primary packaging could then be placed in a secondary packaging and secured in a manner that#

Page 2prevents any puncture, tear, or breakage of the packaging materials. Further, the performance tests in § 178.609 require the packaging to be dropped on its bottom, top, sides, and corner, and cold-conditioned and immersed in water with no leakage from the primary receptacle. Additional requirements in §§ 173.196 and 178.609 may also apply. I hope this satisfies your request. Sincerely, ~~~-- T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division 2#

Page 3t...avnon~Yl § 17 3-Jq~ § 173 ./qqDrakeford. Carolyn (PHMSA) From: INFOCNTR (PHMSA) -:t=rtf'ofchoLls Substances Sent: Wednesday, August 11, 2010 10:34 AM To: Drakeford, Carolyn (PHMSA) 10- 0111 Subject: FW: Shipping Category A infectious substances From: Talburt, Chuck D (DOH) [mailto:Chuck.Talburt@DOH.WA.GOV] Sent: Tuesday, August 10, 2010 5:32 PM To: INFOCNTR (PHMSA) Subject: Shipping Category A infectious substances To Whom It May Concern, This is a follow up from a previous email on this subject. I am interested in knowing specifically whether Category A, infectious substances, can be shipped by either ground or air using Petri dishes as primary containers. References 08-0276 and 08-0158 clarify the use of Petri dishes as primary containers for Category B cultures. However, I am concerned that laboratories in our state may be sending in Category A, infectious substances, using Petri dishes as primary containers. We are concerned particularly regarding possible anthrax cultures. Could you please forward an interpretation regarding this question? Thank you for your assistance in this matter. Please address your response to: Chuck Talburt Washington State Public Health Laboratories 1610 N E 150th Street Shoreline, Washington 98155 Chuck Talburt Laboratory Program Advisor phone: (206) 418-5404 email address: ChuckTalburt@doh.wa.gov "The Department of Health Works to Protect and Improve the Health of People in Washington State" 1#