{"operation":"document","citation":"12-0247","title":"Curtis Bay Energy — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2013-05-23","effective_on":null,"summary":"12-0247 response to Curtis Bay Energy concerning 173.134, 173.197, 178.602.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0247.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0247.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-12-0247","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2012/120247.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1 200 New Jersey Ave, SE\nWashington, D.C. 20590\nMAY 2 3 2013\nMr. Edward Petrullo\nDirector, EH&S\nCurtis Bay Energy\n3200 Hawkins Point Road\nBaltimore, MD 21226\nReference No. 12-0247\nDear Mr. Petrullo:\nThis is in response to your October 25 and 26, 2012 e-mails; October 22, 2012 telephone call with\na member of my staff; and October 23,2012 conference telephone call with employees of Curtis\nBay Energy and a member of my staff. You ask if two different United Nations (UN) 4H2 red\npolyethylene containers with polyethylene lids designed to transport a \"UN 3291, Regulated\nmedical waste, n.o.s., 6.2 (Category B infectious), Packing Group (PG) II,\" (RMW) including\nsharps, comply with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) when\ntransported in different packaging configurations. We summarized the descriptions you provided\nfor each packaging and paraphrased and answered your questions below.\nPackaging 1: UN 4H2 with Sliding Lid\nYou enclosed a test report prepared by Container-Quinn Testing Laboratories, Inc., for Rotonics\nManufacturing, Inc., that describes the first packaging as a 17-gallon oblong, trapezoid-shaped,\nred-polyethylene container with handles, and with extended edges on both longitudinal sides on\nthe top of the packaging that would permit it to be suspended from the side rails of an\nappropriately sized wheeled-metal rack. The test report also states the polyethylene lid on this\npackaging slides and locks, is securely closed with a 1/8th-inch wide reinforced polyethylene\ncable tie, and that the packaging can be stacked. In addition, the test report states this container's\ni1mer packagings consist of RMW contents placed inside one 3-ml red polyethylene bag with a\nbottom seam that is heat-sealed and a top that is twisted and knotted tightly closed. This bag is\nthen placed inside of another identical polyethylene bag that is also closed in the same manner.\nThe test report describes the inner packaging's test contents as consisting of a one-gallon sharps\ncontainer, one gallon of water in four one-quart glass jars, miscellaneous polyethylene test tubes,\nrags, paper and cloth towels, empty glass jars, polyethylene trays, corrugated paper, and paper\ndunnage that together weigh a total of 21.3 pounds. The test report further states the gross weight\nofthe completed package is 28.4 pounds (12.9 kg) and the package is marked ''UN 4H2/Y\n12.9/S/**/USA/CQ 12160,\" but does not include drawings or a photograph of the packaging. You\nprovided photographs of these packagings, both empty and filled.\n\n<<<PAGE 2>>>\n\nPackaging 2: UN 4H2 with Hinged Lid\nYou enclosed a test report prepared by Gaynes Labs, Inc., for the Rehrig Pacific Company that\ndescribes the second packaging as a 17-gallon oblong, trapezoid-shaped, red-polyethylene\ncontainer with two integral handles and extended edges on both longitudinal sides on the top of\nthe packaging that would permit it to be suspended from the side rails of an appropriately sized\nmedical waste transport rack. The test report also states that the packaging has a rectangular\npolyethylene (main) lid attached to its base by a continuous hinge located on one long side at the\ntop of the packaging, a second inner (sub) lid attached to the main lid by three hinges and one\nlatch, and that the packaging can be stacked. In addition, the test report describes the test contents\nfor this packaging as consisting of a solid mixture of sand and vermiculite placed directly inside\neach packaging without any liner to a maximum fill capacity of95% and a gross weight of22.6\nkg. The test report includes two drawings of the packaging and states it is marked \"UN 4H2/Y\n22.6/Sill!USA/+AB2091.\" You did not provide a photograph of this packaging.\nQuestions\nQl. Do both packagings comply with the HMR when transporting RMW: 1) on the floor of a\ntruck as an individual packaging; 2) inside of a fiberboard box; 3) strapped or shrink-\nwrapped to a pallet; or 4) suspended in rows from a wheeled-metal rack?\nAl. A polyethylene box that meets the requirements in the HMR for a UN 4H2 packaging\nat the PG II performance level is an authorized hazardous materials packaging. Provided it\ncomplies with all applicable requirements of the HMR, including being prepared and\nclosed for transportation in the manner described in the manufacturer's closure\ninstructions, a completed authorized package containing RMW may be transported:\n• As a single package;\n• On the floor of a truck if properly secured and blocked against shifting, including motion\nbetween packages (see § 177.834(a)); and\n• Inside an overpack, as defined in§ 171.8, such as inside a fiberboard box, strapped or\nshrink-wrapped to a pallet, or properly enclosed and suspended from the side rails of a\nwheeled-metal rack.\nHowever, please note to demonstrate the packaging's puncture resistance for sharps and\nsharps with residual fluids, § 173.197 (b) requires that before they are performance tested\nnon-bulk RMW packagings used as sharps containers must be filled with materials\nrepresentative of the sharps and fluids (such as sterile sharps) intended to be transported in\nthe packagings. Section 178.602(c) also states:\nIf the material to be transported is replaced for test purposes by a non-hazardous\nmaterial, the material used must be of the same or higher specific gravity as the\nmaterial to be carried, and its other physical properties (grain, size, viscosity) which\nmight influence the results ofthe required tests must correspond as closely as\npossible to those of the hazardous material to be transported. Water may also be\n2\n------------------- -- - -------\n\n<<<PAGE 3>>>\n\nQ2. A2. used for the liquid drop test under the conditions specified in§ 178.603(e) and\nadditives, such as bags of lead shot, to achieve the requisite total package mass, so\nlong as they are placed so that the test results are not affected. See § § 173.197 (b)\nand 178.602(b) and (c).\nBased on the test report prepared by The Rehrig Pacific Company, the UN 4H2 packaging\nwith the hinged lid (Packaging 2) passed the tests at the PG II performance level to\ntransport materials with the same physical characteristics present in a solid sand-\nvermiculite mixture but has not passed tests authorizing it to transport sharps, as this term\nis defined in § 173 .134( a)( 6), and liquids, as this term is defined in § 171.8. In addition,\nthe HMR permits sharps to be transported in non-bulk, non-specification sharps\npackagings that meet the general packaging requirements in 49 CFR 173.24 and 173 .24a,\nand the U.S. Department of Labor's bloodborne pathogen requirements in 29 CFR\n1910.1030 when transported by only private or contract carrier. See§ 173.134(c)(l)(ii).\nBecause the packaging you described is an authorized UN standard packaging, it may also\nbe placed inside of an overpack. An overpack is a container or enclosure used by a single\nconsignor to provide protection or convenience in handling or to consolidate two or more\npackages (see § 171.8). Examples of an overpack include packages: 1) placed or stacked\non a pallet that are secured to it by strapping, shrink wrapping, stretch wrapping, or other\nsuitable means; or 2) placed in a protective outer packaging, such as a box, crate, or\nwheeled-metal rack. For a completed authorized package of hazardous material to be\nplaced in an overpack, it must comply with the requirements prescribed in§ 173.25, which\ninclude the following:\n• Forbidden hazardous materials and packages, as prescribed in § 173.21, are not permitted;\n• The authorized package must comply with general packaging requirements prescribed in\n§ 173.24;\n• When applicable, required marks and labels representing each of the hazardous materials\ncontained in an authorized package must be visible when one or more of these packages is\nplaced in an overpack, if they are not, this information must be repeated on the outside of\nthe overpack; and\n• When packagings placed inside of the overpack are required to be Department of\nTransportation (DOT) specification or UN standard packagings and the marks that specify\nthe package's design type are not visible, the word \"OVERPACK\" must be marked on the\noutside of the overpack.\nMust we use a wheeled cart if our 17 -gallon reusable container is not gasketed?\nNo. Based on the infonnation you provided, both packagings satisfied the HMR's\nperformance tests without the use of gaskets; therefore, placing them in a wheeled cmi or a\nwheeled-metal rack is not required. However, a wheeled cart or wheeled-metal rack may\nbe used as an overpack as described in Answer A 1.\n3\n\n<<<PAGE 4>>>\n\nQ3. Is a gasket required on a packaging for it to be \"leak proof'?\nA3. No. A packaging is considered leakproof under the HMR if it satisfies the leakproofness\ntest prescribed in§ 178.604. However, please note inner packagings of combination\npackagings are not subject to the leakproofness test requirements of§ 178.604 (see\n§ 178.604(a)(2)).\nQ4. Are we allowed to use \"secondary containment\" for our 10- and 17 -gallon containers if we\ndo not use a wheeled cart?\nA4. Yes, see Answer AI.\nQ5. A5. Q6. A6. Q7. A 7. Q8. Can a container that has a third-party testing lab performance-orientated package testing\ncertification stand on the floor of a trailer or truck without a cart?\nYes, provided it is properly blocked and braced. See Answer AI.\nThe Rotonics 17-gallon (Packaging 1) container was tested using two itmer red bags.\nPlease advise what our transportation options are for this packaging under the HMR if we\nadd additional red bags to the container, and what they are if we remove the red bags.\nAny change in structural design (such as the addition or removal of packaging\ncomponents), size, material of construction, wall thickness, or manner of construction to a\nUN 4H2 packaging constitutes a different packaging under the HMR that is subject to\ndesign qualification testing (see§ 178.601(c)(4)). However, the HMR permits selective\ntesting of non-bulk packagings that differ in only minor respects from tested designs as\nspecified in § 178.601 (g).\nIs use of a wheeled cart or rack required to have a Special Permit if we transport reusable\nsharps containers?\nIf a hazardous materials packaging is authorized as acceptable in transportation under tlfe\nHMR, it may be transported using a consolidation device like a wheeled cart or rack\nwithout having to operate under the terms of a Special Permit. An unauthorized packaging\nthat contains a hazardous material must not be offered for or entered into transportation in\ncommerce without a competent authority approval in the form of a written Special Permit\nor Approval, as these terms are defined in § 1 07.1, that is issued by the Competent\nAuthority of the United States, the Associate Administrator of Hazardous Materials Safety.\nThe procedures for applying for a Special Permit or to become a party to an existing\nSpecial Permit are found in 49 CFR Part 107, Subpmi B. The procedures for applying for\nan Approval are found in 49 CFR Part 107, Subpart H. For a more detailed explanation of\nthis application process, see Answer A9.\nYou state the owner of Solutions, Inc., told your company through a distribution agreement\nthat your company may use his wheeled racks and containers without separately applying\n4\n\n<<<PAGE 5>>>\n\nA8. Q9. A9. for a Special Permit and ask if this statement is true? You state his Special Permit number\nis DOT-SP 13556.\nThe use of a Special Permit may not be authorized through a private company's\ndistribution agreement. As stated in Answer A 1, an authorized hazardous materials\npackaging may be placed inside of an unauthorized packaging, like a wheeled rack, that is\nused as an overpack without having to apply for specific relief from the HMR under the\nterms of a Special Permit or Competent Authority Approval. An unauthorized packaging\nmust not be used to transport a hazardous material in commerce without the specific\nauthorization of the Associate Administrator of the Office of Hazardous Materials Safety.\nYou also ask what your company would need to do to apply for a Special Permit if it were\nto design its own wheeled cart?\nTo initate a request for a new Special Permit, your company may wish to submit an\napplication to the Associate Administrator for Hazardous Materials Safety that conforms\nwith the requirements prescribed in 49 CFR Part 107, Subpart B. The application must\ncontain sufficient information to demonstrate that, if a Special Permit is issued, the method\nof relief requested achieves a level of safety that is equal to or greater than that required\nunder the HMR. You may also obtain this information from our website at\nhttp://www. phmsa. dot. gov /hazmat/regs/ sp-a.\nPackages authorized under a Pipeline and Hazardous Materials Safety Administration\n(PHMSA) Special Permit (DOT-SP) do not otherwise comply with the HMR, and must be\nexamined and approved for use by PHMSA's Associate Administrator for Hazardous\nMaterials Safety. If your company chooses to apply for a Special Permit, it must include\nin its application sufficient information about the packaging's design and performance to\nprove the packaging meets or exceeds the requirements prescribed in the HMR for the\nhazardous material intended for the packaging. Also, to learn who may use a packaging\nauthorized under existing Special Permit DOT-SP 13556, please contact the Approvals and\nPermits Division at either (202) 366-4535 or (202) 366-4511.\nI hope this satisfies your request.\nSincerely,\n~/~~-\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n5\n\n<<<PAGE 6>>>\n\n:Jrakeford, Carolyn (PHMSA)\nfrom:\nSent:\n'1'o:\nSubject: Attachments: Edmonson, Eileen (PHMSA)\nFriday, October 26, 2012 6:20PM\nDrakeford, Carolyn (PHMSA)\nFW: 911------ Fwd: Special Permit\nHow to UNZIP.html; SecureZIP Attachments.zip\nCarolyn-\nPlease log this e-mail in and assign it to me for response. The sections discussed by order of importance are:\n§§ 173.197(b),\n178.602(b) and (c),\n173.134(a)(6),\n173.24,\n173.24a,\n107.107,\nand\n171.16.\nI also have 2 test reports to include with the original.\nThanks,\nEileen Edmonson\nUSDOT/PHMSA\n(202) 366-4481 (w)\n(202) 366-7041 (f)\neileen.edmonson@dot.gov (e-mail)\nhttp://www.phmsa.dot.gov/hazmat (website)\ninfocntr@dot.gov (Hazmat Info Center E-mail)\nFrom: Edward Petrullo [mailto:epetrullo@curtisbayenergy.com]\nSent: Thursday, October 25, 2012 12:02 PM\nTo: Edmonson, Eileen (PHMSA)\nSubject: Re: 911------ Fwd: Special Permit\nI will try again but it does show up on my computer and e-mail. Basically their container is 17 gallon with no\ntesting using any red bags and is approved. They did use 50 pounds of wet sand and vermiculite and no \"sharps\"\nor materials one would argue maybe they should. Can you address the dialog and questions from Debbie. What\ndoes the country now do that use 17 gallon rotonics? Solutions stated today their wheeled carts and containers\nthey distribute can be usedaccording to thier interactions with DOT through the purchase and distribution\nagreements. In other words, we are users of the special permit. We do not need to separately go get one. But the\nspecial permit is not a regualtion and we do not have to follow it if we care to place 17 gallon containers in\nsecondary containers, shrink wrap on a pallet, or place on the floor. Thoughts?\nOn Thu, Oct 25,2012 at 10:07 AM, <eileen.edmonson@dot.gov> wrote:\nEd- The adobe acrobat file would not open because it is damaged. Can you check it and send it again?\nEileen Edmonson\nUSDOT/PHMSA\n(202) 366-4481 (w)\n(202) 366-7041 (f)\neileen.edmonson@dot.gov (e-mail)\nhttp://www.phmsa.dot.gov/hazmat (website)\n1\n\n<<<PAGE 7>>>\n\ninfocntr@dot.gov (Hazmat Info Center E-mail)\nFrom: Edward Petrullo [mailto:epetrullo@curtisbayenergy.com]\nSent: Thursday, October 25, 2012 9:00 AM\nTo: Edmonson, Eileen (PHMSA)\nSubject: 911------ Fwd: Special Permit\nDear Eileen,\nPlease read the below reaction by our satellite office. I can tell you that these folks are not very knowledgeable on\nregs in general and the terminology confuses them. You can see the \"sky is falling\" reaction. Can you send on a\nclean e-m.ail answers to the points Debbie writes. They have already had it explained that the Stericycle's special\npermit (others have applied to be users) was relief for using a non-leak proof BOP- the wheeled cart. Tracy only\nbeing with Stericycle in this industry has convinced Debbie that special permit is a regulation and everyone using\nreusable sharps containers must comply. I think we confused folks the other day by first saying \"secondary\ncontainment\" is one remedy that most of the industry uses and then later you said we had to test any out package\nwe used for the 17 gallon. If 2 liners and needed and those 17 gallon containers cannot sit on the floor of a truck,\n95% of the medical waste haulers in the country are out of compliance and the industry could freak out. I believe\nyou can address whether the 17 gallon container can have a red bag or two put on its outer package (if they are\nresistant to placing 2 bags inside the container as I have tried to suggest as a remedy). I also think we can place\nthese containers in a box and bag, or a 96 gallon tote, or a 200 gallon tote, or how about on a pallet and shrink\nwrap for transport four high and five across (for example).\nI can tell you that our new management needs to clearly have something of a remedy in writing and Debbie will\ncontinue to argu things like 3 mil lines can leak. These liners must be ASTM certified passing the dart and tear\ntests. Rarily is there amy liquids in containers and more rarily do red bags break at the 3 1 thickness. We have no\nhistoru of spills or containers falling over. We have been transporting 300 of these 17's on a truck floor bi-weekly\nfor years. Can you please help us to simply have a way to proceed without all the maybe's. The Snyder Corp\nshould be reprimanded perhaps for their testing process and then not having a matching closure doc. It says no\nsharps in that doc as well confusing the consumers. I am adding a new container just FDA approved that is tested\nfor 50 pounds and without red bags inside. This Rehrig-Pacific 17 and 10 gallon can sit on the tloor withour a\nwheeled cart. see attached and please let me have in writing something this week.\nAre there any interpretations on wood floors in trailers or medical waste box trucks?\nThanks.\nOn Wednesday, October 24,2012, Debbie Schlarb <dschlarb@curtisbayenergy.com> wrote:\n> Good Morning,\n>\n> Per our conference call yesterday, are we to understand that we are out of compliance with the special permit\nsince we do not have it under Curtis Bay Energy's name? If this is so, are we transporting sharps containers\nillegally?\n>\n>We need immediate clarification on what was said via the conference call as there was no resolution given\neither way before the call ended. From what Tracy and I interpreted from Eileen's comments were as follows:\n>\n> 1. When Ed stated to Eileen that Victor from Solutions said we can use \"his\" Special Permit, her response was\n\"is solutions a parent company to CBE?\" So my question is .. can we use Victor's Special Permit in our trucks that\nhaul the reusable sharps, because no answer was given.\n>\n> 2. Per Eileen, the packaging of the containers can stand alone in the trucks per Snyders closure instructions,\nwhich was inconclusive as to what was actually tested as there is no mention of a 17 gallon reusable sharps\ncontainer. Per Snyders own notation which states, \"Containers are not intended for use with loose sharps or sharp\n2\n\n<<<PAGE 8>>>\n\nitems. Eileen also stated it was very unclear to her as to what was tested. So my question is ... are we in\ncompliance?\n>\n>\n>Regards,\n>\n>Deborah J. Tisdale\n> District Manager\n> Curtis Bay Energy\n> I would like to get the final answer on the above 2 questions so we can move forward.\nEdward Petrullo\nDirector, EH&S\nCurtis Bay Energy\nepetrullo@curtisbayenergy.com\nCell: 602-625-5002\nCurtis Bay Energy\n3200 Hawkins Point Road\nBaltimore, Maryland 21226\nF: 800-699-0972\nhttp://www.curtisbayenergy.com\nr;l;, Be Green. Read it on-screen.\n3\n\n<<<PAGE 9>>>\n\n· Drakeford, Carolyn (PHMSA)\nFrom:\nSent:\nTo:\nSubject: Attachments: Edmonson, Eileen (PHMSA)\nFriday, October 26, 2012 6:20PM\nDrakeford, Carolyn (PHMSA)\nFW: 911------ Fwd: Special Permit\nHow to UNZIP.html; SecureZIP Attachments.zip\nFrom: Edward Petrullo [mailto:epetrullo@curtisbayenergy.com]\nSent: Thursday, October 25, 2012 12:02 PM\nTo: Edmonson, Eileen (PHMSA)\nSubject: Re: 911------ Fwd: Special Permit\nI will try again but it does show up on my computer and e-mail. Basically their container is 17 gallon with no\ntesting using any red bags and is approved. They did use 50 pounds of wet sand and vermiculite and no \"sharps\"\nor materials one would argue maybe they should. Can you address the dialog and questions from Debbie. What\ndoes the country now do that use 17 gallon rotonics? Solutions stated today their wheeled carts and containers\nthey distribute can be usedaccording to thier interactions with DOT through the purchase and distribution\nagreements. In other words, we are users of the special permit. We do not need to separately go get one. But the\nspecial permit is not a regualtion and we do not have to follow it if we care to place 17 gallon containers in\nsecondary containers, shrink wrap on a pallet, or place on the floor. Thoughts?\nOn Thu, Oct 25, 2012 at 10:07 AM, <eileen.edmonson@dot.gov> wrote:\nEd- The adobe acrobat file would not open because it is damaged. Can you check it and send it again?\nEileen Edmonson\nUSDOT/PHMSA\n(202) 366-4481 (w)\n(202) 366-7041 (f)\neileen.edmonson@dot.gov (e-mail)\nhttp://www. phmsa. dot.gov/hazmat (website)\ninfocntr@dot.gov (Hazmat Info Center E-mail)\nFrom: Edward Petrullo [mailto:epetrullo@curtisbayenergy.com]\nSent: Thursday, October 25, 2012 9:00AM\nTo: Edmonson, Eileen (PHMSA)\nSubject: 911------ Fwd: Special Permit\nDear Eileen,\nPlease read the below reaction by our satellite office. I can tell you that these folks are not very knowledgeable on\nregs in general and the terminology confuses them. You can see the \"sky is falling\" reaction. Can you send on a\nclean e-mail answers to the points Debbie writes. They have already had it explained that the Stericycle's special\npermit (others have applied to be users) was relief for using a non-leak proof BOP - the wheeled cart. Tracy only\nbeing with Stericycle in this industry has convinced Debbie that special permit is a regulation and everyone using\nreusable sharps containers must comply. I think we confused folks the other day by first saying \"secondary\ncontainment\" is one remedy that most of the industry uses and then later you said we had to test any out package\nwe used for the 17 gallon. If 2 liners and needed and those 17 gallon containers cannot sit on the floor of a truck,\n95% of the medical waste haulers in the country are out of compliance and the industry could freak out. I believe\nyou can address whether the 17 gallon container can have a red bag or two put on its outer package (if they are\nresistant to placing 2 bags inside the container as I have tried to suggest as a remedy). I also think we can place\nthese containers in a box and bag, or a 96 gallon tote, or a 200 gallon tote, or how about on a pallet and shrink\nwrap for transport four high and five across (for example).\n1\n\n<<<PAGE 10>>>\n\nI can tell you that our new management needs to clearly have something of a remedy in writing and Debbie will\ncontinue to argu things like 3 mil lines can leak. These liners must be ASTM certified passing the dart and tear\ntests. Rarily is there amy liquids in containers and more rarily do red bags break at the 3 1 thickness. We have no\nhistoru of spills or containers falling over. We have been transporting 300 of these 17's on a truck floor bi-weekly\nfor years. Can you please help us to simply have a way to proceed without all the maybe's. The Snyder Corp\nshould be reprimanded perhaps for their testing process and then not having a matching closure doc. It says no\nsharps in that doc as well confusing the consumers. I am adding a new container just FDA approved that is tested\nfor 50 pounds and without red bags inside. This Rehrig-Pacific 17 and 10 gallon can sit on the floor withour a\nwheeled cart. see attached and please let me have in writing something this week.\nAre there any interpretations on wood floors in trailers or medical waste box trucks?\nThanks.\nOn Wednesday, October 24,2012, Debbie Schlarb <dschlarb@curtisbayenergy.com> wrote:\n> Good Morning,\n>\n> Per our conference call yesterday, are we to understand that we are out of compliance with the special permit\nsince we do not have it under Curtis Bay Energy's name? If this is so, are we transporting sharps containers\nillegally?\n>\n>We need immediate clarification on what was said via the conference call as there was no resolution given\neither way before the call ended. From what Tracy and I interpreted from Eileen's comments were as follows:\n>\n> I. When Ed stated to Eileen that Victor from Solutions said we can use \"his\" Special Permit, her response was\n\"is solutions a parent company to CBE?\" So my question is .. can we use Victor's Special Permit in our trucks that\nhaul the reusable sharps, because no answer was given.\n>\n> 2. Per Eileen, the packaging of the containers can stand alone in the trucks per Snyders closure instructions,\nwhich was inconclusive as to what was actually tested as there is no mention of a 17 gallon reusable sharps\ncontainer. Per Snyders own notation which states, \"Containers are not intended for use with loose sharps or sharp\nitems. Eileen also stated it was very unclear to her as to what was tested. So my question is ... are we in\ncompliance?\n>\n> I would like to get the final answer on the above 2 questions so we can move forward.\n>\n>Regards,\n>\n>Deborah J. Tisdale\n> District Manager\n> Curtis Bay Energy\nEdward Petrullo\nDirector, EH&S\nCurtis Bay Energy\nepetrullo@curtisbayenergy.com\nCell: 602-625-5002\nCurtis Bay Energy\n3200 Hawkins Point Road\n2\n\n<<<PAGE 11>>>\n\nBaltimore, Maryland 21226\nF: 800-699-0972\nhttp:/ /www.curtisbayenergy.com\nJJ Be Green. Read it on-screen.\n3\n\n<<<PAGE 12>>>\n\n-·\nReport No.: 12160\nRe: SDC l7Gall3\" Opening Red with Transport Lid\nDate ofReport: 3/21/11\nDate of Revision: dna\n•\nCONTAINER-QUINN\nTESTING LABORATORIES, INC.\nA division ofH.H. Holmes Testing Laboratories, Inc.\n® 170 Shepard A\\'Cllue, Wheeling,IL 60090\nPhone: 847·537-9470 Ha:<: 847-537-9098\nE-Mail: spo\"l.lll@~ntainer-quinn.com\n3rd PARTY TESTING lABORATORY\nPERFORMANCE ORIENTED PACKAGE TESTING CERTIFICATION\nPerformed by:\nContainer-Quinn Testing Laboratories, Inc.\n170 Shepard Avenue\nWheeling, ll60090\nTesting Performed for:\nRotonics Manufacturing, Inc.\nAttn.: Susan B. Hornat\n736 Birginal Drive\nBensonville, IL 60106\n630-773-9510\nDesign Qualification Testing for a\nUN 4H2 17 -gallon oblong openhead Plastic container with sliding transport cover containing\ntwo (2) 3-mil polyetylene red bags (one inside the other)\nf7i\\ 4H2 /Y 12.9/ S /.,.\n\\_V USA I CQ12160\n*\" is to be replaced by the year of box manufacturer\nCertification Expires: 3/21/13\nCONTAINER-QUINN TESTING LABORATORIES, INC.\nI\nSteptlen C. Powell • Laboratory Director\n/\nAS A MUlUAL PROTECTION FOR OUR CLIENTS AND OURSELVES, ALL REPORTS ARE SUBMITI'ED AS THE CONFIDENTIAL\nPROPERTY OF OUR CLIENTS, AND At11HORIZATION fOR PUBLICATION lS RESERVED Ph'NDINO WRITIEN APPROVAL.\neAMPLES Wll.L BE OISPOSEOOF 30 DAYS AFTER TESTING IS COIAJ>I.ETEO UNI.ess OTiiERAARANGEMENTS ARE AGREEO TO mWRrr!NG\n------·-·------------------·\n\n<<<PAGE 13>>>\n\nRotonics·Manufacturing, Jnc . Report No.: 12160\nSection 1\n• ®\nBox: See Appendix A for Drawing and/or Plcture(s)\nManufacturer: Rotonics Manufacturing, Inc., Bensenville, IL\nBox Description: 17 -gallon, oblong, poly unit with handles and slide top transport\ntop with 1/8\" wide reinforced plastic cable tie closures\nMaterial: llDPE\nPart Number: SOC 17GAL\nOuter Dimensions:\n181/4\" X 131/4\" X 25\"\nTare Weight:\n6.9 lbs. with transport lid\n6.1 lbs. alone\nDescription: 17 -gallon, tapered to nest and stack, with sliding and locking\ntransportation lid\nInner Bag: See Appendix A for Drawing and/or Picture(s)\nManufacturer: Solutions, Inc., KY\nMfg. Method: Blowmolded\nPart Number: misc.\nMaterial: llDPE\nSidewall Thickness: 3-mil\nBag Information: 3-mil Red Bag with heat sealed bottom seal, twisted and\nknotted tightly.\nQuantity: 2 - one inside the other and sealed together\n(\nAdditional Test Information\nOverall Weight of Package:\nOverall Tare Weight of Package:\nTest Contents:\nAuthorized Package Gross Wgt:\n28.4lbs. (12.9 kg}\n7.1lbs\nPoly red bag containing one (1) 1-gallon oblong\nsharps containers, 1-gallon water in (4} 1-quart\nglass jars, mise plastic test tubes along with misc.\nrags, paper and cloth towels. empty glass jars,\nplastic trays, corrugated and paper dunnage to\nequal 21.3 lbs.\n26.4 lbs. (12.9 kg)\nClosing Methods:\nPlastic Tote Shipper:\nSealing Method: (2) 1/8\" wide reinforced plastic cable tie closures snuggly secured\n(\nPage2\nCONTAINER·QUINN TESTING LABORATORIES, INC.\n\n<<<PAGE 14>>>\n\nRotonics Manufacturing, Inc. Report No.: 12160\nSection 2\nTest Descriptions and Results\nPackage Preparation - For All Testing\nThe packages were filled to capacity with miscellaneous dunnage fill materials\nDROP TEST\nTest Method:\n#Test Packages:\nDrop Height:\nEquipment:\n49CFR 178.603\n5\n1.2 meters (47.25\") Split Table Drop Tester\n(Calculation for drop height is provided in Appendix B)\nTesting was conducted to certify the package for PGII\nConditioning:\nThe packages were conditioned to -18+1-3° C and Ambient RH, in accordance with 49CFR 178.603(c).\nThe packages were conditioned for 48 hours to ensure the package and contents were at the proper\ntemperature prior to testing. Drop testing was conducted approximately 5-minutes after removal of the\ntest package from the conditioning chamber.\nResults\n(\nBox\nNumber\n1\n2\n3\n4\n5\nPackage\nWeight Orientation\n28.4 lbs. Bottom, Mfg. Corner\n28.4 lbs. Flat on short side\n28.4 lbs. Flat on long side\n28.4 lbs. Flat on top\n26.4 lbs. Flat on bottom\nResults\nPass - no damage\nPass - no damage\nPass - no damage\nPass - no damage\nPass - no damage\nno release of the Inner packages from the outer\npackage, no leakage of the filling substance from\nthe bottles noted\nPass/Fail Criteria -\nA package Is considered to successfully pass the drop tests if for each sample tested: There is no\ndamage to the outer packaging likely to adversely affect safety during transport, there is no leakage of the\nfilling substance from the inner packaging and any discharge from a closure is slight and ceases\nimmediately after impact.\nSpecial Note:\nAfter each drop test, test product was removed from test polybag. 2-gallons water was placed in the polybags\nand polybags were laid on first one side and then the other for 15-minutes each. No leakage was noted. Dual\npolybags retained water. Polybags were then reincerted in container, lid placed in closed position and\ncontainer was inverted for 2-hours with no leakage\nPage3\nCONTAINER-QUINN TESTING lABORATORIES, INC.\n\n<<<PAGE 15>>>\n\nRotonics Manufacturing, Inc . Report No.: 12160\n(\n• ®\nSTACKING TEST\nTest Method:\n#Test Packages:\nMethod:\nTest Duration:\n49CFR 178.606\n3\nFree Standing\n24-hours\nConditioning:\nThe packages were conditioned to 23+/-3° C and 50+/-5% RH, in accordance with 49CFR 178.602(d).\nStack Weight (lbs): 110 {See Appendix B for calculation)\nThe stacking test load was applied to the top of the packages by loading each package with the\ncalculated weight and maintaining that weight for a minimum of 24-hours.\nResults:\n1 Passed . 2 Passed 3 Passed No damage to the packaging, normal and expected packaging fatigue and crush\nNo damage to the packaging, normal and expected packaging fatigue and crush\nNo damage to the packaging, normal and expected packaging fatigue and crush\n(\nPass/Fall Criteria -\nNo test sample may leak. There must be no leakage of the filling substance from the inner receptacle or\ninner packaging. No test sample may show any deterioration which could adversely affect transportation\nsafety or any distortion likely to reduce its strength, cause instability in stacks of packages, or cause\ndamage to inner packagings likely to reduce safety in transportation.\nPage4\nCONTAlNER·QUlNN TESTING LABORATOR!E.S,!NC.\n\n<<<PAGE 16>>>\n\nRotonics Manufacturing, Inc.\nReport No.: 12160\nREPETITIVE SHOCK VIBRATION TEST\nTest Method:\n#Test Packages:\nMethod:\nTest Duration:\nFrequency:\nEquipment:\nDisplacement:\n49CFR 178.608\n3 one same table\nRepetitive Shock\n1-hours\n4.0 Hz {239 cpm)\nLansmont Vibration Table\n1\"\nConditioning:\nThe packages were conditioned to 23+/-3° C and 50+/-5% RH, in accordance with 49CFR 178.602(d).\nResults:\n1 Passed 2 Passed 3 Passed No damage to the packaging, normal and expected packaging fatigue and crush\nNo damage to the packaging, normal and expected packaging fatigue and crush\nNo damage to the packaging, normal and expected packaging fatigue and crush\nPass/Fall Criteria -\nNo test sample may leak. There must be no rupture or leakage of the filling substance from any packages.\nNo test sample may show any deterioration which could adversely affect transportation safely or any\ndistortion likely to reduce packaging strength\nPageS\nCONTAINER-QUINN TESTING lABORATORIES, lNC.\n\n<<<PAGE 17>>>\n\nRotonics Manufacturing, Jnc.\nReport No.: 12160\n(\nAppendix A\nDrawings and/Or Pictures of Packaging Components\nSee aUached photos, drawings and specification sheets\nAppendixB\nCalculations\n1. Weight of test package:\nTotal Gross Weight of Sample: 28.4 lbs. {12.9 kg)\n!\n\\\n2. Drop Test Height\nPackage Group of Certification\nDrop Height for PG II\nSpecific Gravity\nCalculation for PG II\nDrop Height for PG II\n(1.2x1.0)\n(1.2 X 3.2808' X 12)\n1.2 meters\ndna\nSG X 1.2\n1.2 meters\n47.244 inches\n3. Stack Test Weight\nLoad=(118.11-h)/h\"'w\nWhere: 118.11 = height of stack test (3 meters)\nh = height of package as tested and sealed\nw = weight of tested package (lbs.)\nPackage Height:\nWeight of Package;\n25\"\n28.4lbs.\n(118.11-25)/25\n3.7 x28.4\nTest Weight:\n3.724400\n105.8\n110\nAppendlxC\nTest Equipment and Instrumentation\nInstrument/Equipment\nSplit Table Drop Tester\nHydrolic Vibration Tester\nWeight Scale, large\nWeight Scale, small\nManufacturer\nLAB\nLana mont\nGSE\nGSE\nModel Number\n1500$\nGSESOO\nPage6\nCONTAINER-QUINN TESTING LABORATORIES, INC.","truncated":false,"body_characters":34350}