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Interpretation Response #04-0197 ([Bureau of Radiation Protection, Pennsylvania Department of Environmental Protection] [Mr. David J. Allard, CHP, Director])

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

Interpretation Response Details

Response Publish Date:

Company Name: Bureau of Radiation Protection, Pennsylvania Department of Environmental Protection

Individual Name: Mr. David J. Allard, CHP, Director

Location State: PA Country: US

View the Interpretation Document

Response text:

Oct 8, 2004


Mr. David J. Allard, CHP, Director                 Reference No. 04-0197
Bureau of Radiation Protection
Pennsylvania Department of Environmental Protection
Rachel Carson State Office Building
P.O. Box 8469
Harrisburg, PA 17 105-8469

Dear Mr. Allard:

This responds to your August 31, 2004 letter requesting clarification on the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to household wastes that have been contaminated with short-lived medical radionuclides and the use of DOT Exemption 11406. Specifically, you ask whether these contaminated household wastes are regulated as Class 7 hazardous materials under the HMR.

According to your letter and previous email correspondence with this office, some household wastes may become radiologically contaminated by patients (human and animal) who have undergone nuclear medicine procedures, and released to go home. Based on information previously provided to you by this office, it is your understanding that household wastes are not regulated under the HMR. Your understanding is correct. Household wastes, including household wastes contaminated with short-lived radionuclides, are not subject to the HMR.

I hope this answers your inquiry.



Edward T. Mazzullo
Office of Hazardous Materials Standards


Regulation Sections

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