Interpretation Response #02-0270 ([Information From Science, LLC] [Ira F. Salkin, Ph.D., F(AAM)])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 03/21/2003

Company Name: Information From Science, LLC

Individual Name: Ira F. Salkin, Ph.D., F(AAM)

Location State: NY Country: US

View the Interpretation Document

Response text:

Mar 21, 2003

Mr. Era F. Salkin, Ph.D., F(AAM)                    Reference No. 02-0270
Information From Science, LLC
P.O. Box 408
West Sand Lake, NY  12196

Dear Mr. Salkin:

This responds to your October 15, 2002 letter requesting clarification on processing waste body fluids contained in suction canisters in accordance with revisions to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) under Final Rule, Docket HM-226.  Your questions are paraphrased and answered as follows:

Q1. When suction canisters containing three liters or more of waste body fluids are transported for offsite treatment and disposal in non-bulk containers, should they be packed as described in § 173.197, i.e., in packaging that meets DOT'S Packing Group II performance standards?

A1. Waste body fluids may be packaged according to provisions in § 173.197(b) or under exceptions provided in § I 73.134(c) or § 173.6. You are correct that § 173.197 requires non-bulk packagings for regulated medical waste (RMW) to be UN specification packaging conforming to Packing Group II performance requirements in Part 178 of the HMR.  However, § 173.134(c) permits RMW that is transported in dedicated vehicles by private or contract carriers to be packaged in non-specification non-bulk packagings, provided such packagings are rigid and conform to the general packaging requirements in §§ 173.24 and 173.24a of the HMR and Occupational Safety and Health Administration (OSHA) regulations in 29 CFR 1910.1030. In addition, the materials of trade (MOTS) exception in § 173.6 permits RMW to be transported by a private motor carrier in non-specification combination packagings.  For liquid RMW, the inner packagings must be leak-tight and the outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packagings.  The outer packaging must be a strong, tight packaging that is securely closed.  The MOTS exception includes limits on the capacity of a packaging.

Q2. Since I am not aware of any commercially available suction canisters that would meet Packing Group II specifications, would the canisters have to be packaged in Packing Group II type of packaging when transported in bulk containers?

A2. Liquid RMW transported in a bulk packaging, i.e., a large packaging, wheeled cart, or bulk outer packaging, must be packaged in a rigid inner packaging that conforms to the general packaging requirements of Part 173 of the HMR, specifically the general packaging requirements in §§ 173.24 and 173.24a. Such inner packagings need not be UN specification packagings, nor are there performance requirements for the inner packagings.

Q3. Relative to Packing Group II standards, wouldn't the canisters with the waste body fluids have to be placed into plastic bags with sufficient absorbent materials to absorb and retain all liquids during transportation?

A3. There is no requirement for inner packagings of liquid RMW that are transported inside.bulk containers to be placed in plastic bags with absorbent material.

Q4. Do cardboard boxes meet the DOT standards for rigid outer containers or must these containers be composed of more durable materials, e.g., fiberboard?

A4. We have not formally defined the term “rigid” in the HMR. Generally, the requirement for a rigid packaging means a packaging that is not flexible, will retain its shape, and will not yield to knocks, bumps, drops, or other forces that may be encountered during transportation.

I hope this answers your inquiry.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

173.197

Regulation Sections