Interpretation Response #01-0201 ([Rubbermaid Commercial Products] [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: 10/16/2001

Company Name: Rubbermaid Commercial Products

Individual Name: Mr. Michael A. Roby

Location State: VA Country: US

View the Interpretation Document

Response text:

October 16, 2001

Mr. Michael A. Roby                             Reference No: 01-0201
Manager-Technical Service Center
Rubbermaid Commercial Products
3124 Valley Avenue
Winchester, VA 22601

Dear Mr. Roby:

This responds to your letter of July 16, 2001, requesting clarification on manufacturing packagings for regulated medical waste (RMW) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You state that your company manufactures packagings for RMW but you do not provide the inner receptacles.  You provide instructions stating:

–Only solids may be hauled (no semi-liquids or liquids);
–Gross weight may not exceed 27.2 kilograms;
–A 3 mil inner liner must be used (top gathered and tied in a single knot);
–Must be transported by private or contract motor carrier.

Your questions are paraphrased and responded to as follows:

Ql.  Should any reference and/or restriction be made as to particulars of the “solids” being transported?  How close to the type of "mix" tested is the end user required to apply to their “mix” to be hauled?

Al. Any mixture of solid materials may be transported in the above described container provided the maximum gross weight as marked on the packaging is not exceeded, however, the packaging may not be used for sharps unless it has been tested as such.  For your information, the Food and Drug Administration also has requirements for sharps containers.

Q2.  May pressure sensitive labels be used for marking a packaging?  Is there a performance test that labels need to meet?

A2.  Pressure sensitive labels may be used for marking a package.  There is no performance test for such labels.

I hope this information is helpful

Sincerely,

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

173.197, 178.3

Regulation Sections