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Interpretation Response #05-0006

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

Interpretation Response Details

Response Publish Date: 03-08-2005
Company Name: Pro-Pack Testing Laboratory, Inc.    Individual Name: Mr. Manuel Rosa
Location state: IL    Country: US

View the Interpretation Document

Response text:

Mar 8, 2005


Mr. Manuel Rosa, Jr.                 Reference No. 05-0006
President, Pro-Pack Testing Laboratory, Inc.
2385 Amann Drive
Belleville, IL 62220

Dear Mr. Rosa:

This is in further response to your December 22,2004, letter to Don Burger, General Engineer, Office of Hazardous Materials Technology, requesting clarification on how to properly drop test a bulk wheeled-cart packaging for the transport of “Regulated medical waste, 6.2 (infectious), UN 3291, PG II,” under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you stated § 173. 197(d)(2)(iii) requires the drop test for non-bulk packagings prescribed in § 178.603, but provides no guidance on how to perform this test on a bulk wheeled cart. Mr. Burger forwarded your letter to this office for response.

The reference to § 178.603 in § 173.197(d)(2)(iii) is an error. The correct reference is § 178.8 10, which prescribes drop test requirements for intermediate bulk containers (IBCs). Because a wheeled cart is similar in size and structure to an IBC, it was our intention, to require wheeled carts used for the transportation of regulated medical waste to be capable of meeting the drop test requirements in § 178.810 at the Packing Group II performance level. We will correct this error in a future rulemaking. In the interim, you should utilize the drop test requirements in § 178.810. Note that the standard for wheeled carts is a capability standard. Capability may be demonstrated using testing, previous handling or transportation experience, design specifications, or other means.

I hope this information in helpful.



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

173.197, 178.603

Regulation Sections

Section Subject
§ 178.603 Drop test