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Interpretation Response #06-0098 ([PTP Consulting, Inc.] [Ms. Carol Brozosky, CET, 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: PTP Consulting, Inc.

Individual Name: Ms. Carol Brozosky, CET, CHMM

Location State: NJ Country: US

View the Interpretation Document

Response text:

May 11, 2006


Ms. Carol Brozosky, CET, CHMM                Reference No. 06-0098
PTP Consulting, Inc.
1531 Kings Highway
Swedesboro, NJ 08085

Dear Ms. Brozosky:

This responds to your April 22, 2006 letter concerning the applicability of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 17 1-180) to used health care products.
Specifically, you ask whether the HMR apply to used contact lenses returned to the
manufacturer by consumers or healthcare professionals.

For purposes of the HMR, a used health care product is a medical, diagnostic, or research device or piece of equipment or a personal care product contaminated with potentially infectious body fluids or materials (see § 173.134(a)(9)). It is the opinion of this Office that although a used contact lens meets the definition for a used health care product, it is not transported in a quantity or form that would pose a risk to transport workers or the general public. Thus, transportation of used contact lenses being returned by consumers or healthcare professionals is not subject to regulation under the HMR.

I hope this answers your inquiry.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

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