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Interpretation Response #02-0325 ([The Blood Center] [Ruth O'Donnell CHMM])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Blood Center

Individual Name: Ruth O'Donnell CHMM

Location State: WI Country: US

View the Interpretation Document

Response text:

Feb 19, 2003

Ms. Ruth O'Donnell CHMM                   Reference No. 02-0325
Safety Specialist
The Blood Center
638 North 18th Street
Milwaukee, WI 53201-2178

Dear Ms. O'Donnell:

This is in response to your December 4, 2002 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to regulated medical waste.  Specifically, you question if the Materials of Trade (MOTS) exception as revised in the Final Rule, Revision to Standards for Infectious Substances, under Docket No. HM-226, applies to regulated medical waste transported by private motor carriers.

This Final Rule expands the MOTS exceptions currently permitted under § 173.6 of the HMR for hazardous materials carried by private motor carriers engaged in a principal business other than transportation.  The MOTS exceptions apply to Division 6.2 material, other than a Risk Group 4 material, that is a diagnostic specimen, biological product, or regulated medical waste.  The material must meet the definition of a diagnostic specimen, biological product, or regulated medical waste found in § 173.134. The material must be contained in a combination packaging.  For liquids, the inner packaging must be leak tight, and the outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packaging.  For sharps, the inner packaging must be constructed of a rigid material resistant to punctures and leaks.  For all Division 6.2 materials, the outer packaging must be a strong, tight packaging securely closed and secured against movement.  For a regulated medical waste, a combination packaging must consist of one or more inner packaging having a gross mass or capacity not exceeding 4 kg (8.8 pounds) or 4 L (1 gallon), and an outer packaging having a gross mass or capacity not exceeding 16 kg (35.2 pounds) or 16 L (4.2 gallons).

I hope this information is helpful.  If we can be of further assistance, do not hesitate to contact us.


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


Regulation Sections

Section Subject
173.6 Materials of trade exceptions