Interpretation Response #06-0229 ([National Headquarters] [Mr. Michael I. Gorman ])

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

Interpretation Response Details

Response Publish Date: 10/26/2006

Company Name: National Headquarters

Individual Name: Mr. Michael I. Gorman 

Location State: DC Country: US

View the Interpretation Document

Response text:

Oct 26, 2006

Mr. Michael I. Gorman                Reference No. 06-0229
Senior Consultant
NE 704lB
National Headquarters
2025 E Street, NW
Washington, DC 20006

Dear Mr. Gorman:

This is in response to your October 10, 2006 letter requesting clarification of the training requirements provided in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you ask if there were any changes to the training requirements for regulated medical waste shipments prepared in accordance with § 173.197 or § 173.6 of the HMR as a result of the recent rulemaking on infectious substances.

On June 2, 2006 we published a final rule under Docket HM-226A entitled “Hazardous Materials: Infectious Substances; Harmonization with the United Nations Recommendations,” which became effective on October 1, 2006. The rulemaking revised the transportation requirements for infectious substances, including regulated medical waste, to adopt new classification criteria, new exceptions, and packaging and hazard communication requirements consistent with revised international standards and to clarify existing requirements to promote compliance.

Docket HM-226A did not alter the training requirements applicable to the transportation of regulated medical waste. Materials transported under § 173.197 continue to be subject to the training requirements in Part 172, Subpart H of the HMR. When regulated medical waste is transported as a Materials of Trade Exception in accordance with § 173.6, the operator of the motor vehicle must be informed of the presence of the hazardous material and be informed on the requirements in § 173.6, but is not subject the training requirements in Part 172, Subpart H of the HMR.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

173.197(e), 173.6

Regulation Sections