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Interpretation Response #00-0104 ([EnviroTech of America, Inc.] [Mr. Jeffrey A. Paiste])

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

Interpretation Response Details

Response Publish Date:

Company Name: EnviroTech of America, Inc.

Individual Name: Mr. Jeffrey A. Paiste

Location State: NY Country: US

View the Interpretation Document

Response text:

August 2, 2000

Mr. Jeffrey A. Paiste                Reference No. 00-0104
Vice President, EnviroTech of
America, Inc.
P.O. Box 239
East Syracuse, New York 13057

Dear Mr. Paiste:

This is in response to your inquiry and telephone conversations with me and a member of my staff concerning the marking of non-bulk packages that will be used to transport regulated medical waste (RMW) that does not contain a culture or stock of an infectious substance.  You asked if a packaging manufacturer is permitted to mark "UN 3291, PG 11" on the outside of an empty, knocked-down fiberboard box that has not been performance tested without assuming liability for the marking or the packaging.  You also stated the RMW shipments are transported by private or contract carrier.

The answer is yes.  RMW that does not include cultures or stocks of an infectious substance, and is transported by a private or contract carrier is not required to be placed in a packaging meeting the Packing Group II performance level.  Section 173.134(b)(3) authorizes the use of a non-specification packaging for such materials, if certain requirements are met.  Based on the information you provided, your packaging satisfies these requirements.

Further, please note that the proper shipping name ARegulated medical waste@ must also be marked on a package containing RMW.  See §172.301.

I hope this satisfies your request.


Hattie L. Mitchell, C
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.134 Class 6, Division 6.2-Definitions and exceptions