Interpretation Response #00-0091 ([Rubbermaid Commercial Products, LLC] [Mr. Michael A. Roby])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Rubbermaid Commercial Products, LLC
Individual Name: Mr. Michael A. Roby
Location State: VA Country: US
View the Interpretation Document
Response text:
June 6, 2000
Mr. Michael A. Roby Ref. No. 00-0091
Manager, Technical Service Center
Rubbermaid Commercial Products, LLC
3124 Valley Avenue
Winchester, VA 22601
Dear Mr. Roby:
This is in response to your March 29, 2000 letter, and telephone conversations with a member of my staff, concerning the criteria prescribed in 49 CFR 173.197 for regulated medical waste (RMW) packagings. You stated that your packaging, designed for solids only, consists of a polyethylene bag closed with a twist tie and placed inside a non-specification, plastic pail with a removable snap-lock lid. You asked whether a package intended for a solid material is considered to have successfully passed the performance tests if the inner liner (bag) is punctured but the outer packaging remains intact.
The answer is no. The RMW packaging in §173.197 is a UN specific on packaging at the Packing Group II level. If the inner package of a combination package could be opened in any, way, e.g., torn, punctured, ruptured, etc., during routine testing or normal transportation conditions, the package does not meet the general: packaging requirements.
However, the packaging you described is a non-specification packaging. Section 173.134(b)(3) permits RMW to be transported in a non-specification packaging that meets the general packaging requirements in §s173.24 and 173.24a and the packaging requirements specified in 29 CFR 1910.1030. Under §173.24(b), a package used for the shipment of hazardous materials shall be made, filled, and closed so that under normal transportation conditions no hazardous material release can be identified and the effectiveness of the package will not be substantially reduced. For your information, please note that §173.134(b)(3) further requires a non-specification RMW packaging to be marked with the BIOHAZARD mark and transported by private or contract motor carrier.
I hope this satisfies your request.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reirivention
Office of Hazardous Materials Standards
173.197
Regulation Sections
| Section | Subject |
|---|---|
| 173.197 | Regulated medical waste |