Interpretation Response #02-0303 ([Health Care Waste Services] [Joseph Orlando])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Health Care Waste Services
Individual Name: Joseph Orlando
Location State: NY Country: US
View the Interpretation Document
Response text:
May 1, 2003
Mr. Joseph Orlando Reference No.02-0303
Health Care Waste Services
1370 Viele Avenue
Bronx, NY 10474
Dear Mr. Orlando:
This is in response to your letter asking if your company's 1.5 gallon reusable sharps container designed to transport "Regulated medical waste (RMW), 6.2, UN 3291, PG II" must comply with the requirements in 49 CFR 173.197(e)(3) for a sharps inner packaging in a nonspecification bulk packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). We apologize for the delay in responding and any inconvenience this may have caused.
The answer is no. The requirements in § 173.197(e)(3) apply only to a sharps packaging intended for transportation in a large packaging, wheeled cart (Cart), or bulk outer packaging (BOP). However, other requirements in the HMR do apply to non-bulk sharps containers. Section 173.197(b) authorizes the use of a non-bulk single or combination packaging that is puncture-resistant and meets the requirements in Part 178 at the Packing Group II performance level. Section 173.134(c) authorizes the use of a non-bulk, non-specification packaging that meets the general packaging requirements in 49 CFR 173.24 and 173.24a, and those of the U.S. Department of Labor, Occupational Safety and Health Administration, in 29 CFR 1910.1030, provided the sharps are transported by a private or contract carrier. Also, note that § 173.28(f) requires reusable Division 6.2 packagings to be disinfected prior to reuse.
I hope this satisfies your request.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.197
Regulation Sections
| Section | Subject |
|---|---|
| 173.197 | Regulated medical waste |