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Interpretation Response #07-0094 ([MTS Medical Waste Management] [Mr. Edward Petrullo])

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

Interpretation Response Details

Response Publish Date:

Company Name: MTS Medical Waste Management

Individual Name: Mr. Edward Petrullo

Location State: AZ Country: US

View the Interpretation Document

Response text:

Jul 10, 2007

Mr. Edward Petrullo                 Reference No. 07-0094

General Manager and Director

MTS Medical Waste Management

333 North Seventh Avenue

Phoenix, AZ 85007

Dear Mr. Petrullo:

This responds to your May 11, 2007 e-mail and May 31, 2007 telephone conversation with Ms. Eileen Edmonson of my staff concerning requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of regulated medical waste (RMW). Specifically, you ask for a clarification of our letter to Ms. Selin Hoboy, Stericycle, Inc. (Reference No. 07-0057; March 19, 2007) concerning the dedicated vehicle exceptions in § 173.134(c)(2) of the HMR.

The exception in § l73.134(c)(2) permits Category B waste cultures and stocks to be transported as regulated medical waste when packaged in a rigid non-bulk packaging conforming to certain general packaging requirements and transported by a private or contract carrier in a vehicle used exclusively to transport RMW. An exclusive-use vehicle is one used for the transportation of a single commodity or class of commodities. Transportation in an exclusive-use vehicle in accordance with the exception prevents inadvertent contamination of other types of materials, including non-medical waste materials.

In our March 19, 2007 letter to Stericycle, Inc., on this subject, we addressed a question concerning the transportation of other types of materials on the same vehicle as Category B waste cultures and stocks: (1) plant and animal waste regulated by the Animal and Plant Health Inspection Service, U.S. Department of Agriculture; (2) waste pharmaceutical materials; (3) laboratory and recyclable wastes, such as fixer/developer, amalgam, lead foil, and disinfectant materials; (4) infectious substances, including Category A infectious substances, that have been treated to eliminate or neutralize pathogens; (5) forensic materials being transported for final destruction; (6) rejected or recalled health care products; and (7) documents intended for destruction in accordance with HIPAA requirements. While not considered regulated medical waste, as that term is defined in the HMR, all of the listed materials are considered medical waste as that term is usually defined and, according to the information provided by Stericycle, are transported to facilities designated by local authorities and designed for the disposal of medical waste. Moreover, under § 173.134(c)(2), medical or clinical equipment and laboratory products may be transported on the same vehicle as the waste cultures and stocks covered by the exception, provided they are properly packaged and secured against exposure or contamination. The term "laboratory products" is not defined in the HMR. However, the materials described earlier in this paragraph are generated from laboratories and health care facilities and, thus, may be considered laboratory products for the purposes of the exception. For these reasons, we determined that the types of medical waste described in our March 19 letter may be transported on the same vehicle as waste cultures and stocks in accordance with the exception in § 173.134(c)(2).

You ask whether soiled linen and laundry may also be transported on the same vehicle as waste cultures and stocks under the exception provided in § 173.134(c). The answer is no. Soiled linen and laundry are not medical waste and are not transported for disposal at a medical waste facility; further, soiled linen and laundry are not laboratory products as that term is used and understood for purposes of the HMR.

Your email refers to the transportation of soiled healthcare linen on the same vehicle as RMW. We note in this regard that the exception in § 173.134(c) applies only to the transportation of waste cultures and stocks. The HMR do not require shipments of most RMW to be transported on vehicles used exclusively for such transportation. For other than waste cultures and stocks, there are no restrictions on the types of materials that may be transported on the same vehicle as RMW. Thus, you may transport soiled healthcare linen, clean linen, hospital supplies, or other materials on the same vehicle as RMW, provided the shipment does not contain waste cultures and stocks. For purposes of the HMR, "culture" means an infectious substance containing a pathogen that is intentionally propagated. The term does not include human or animal material collected directly from humans or animals and transported for research, diagnosis, investigational activities, or disease treatment or prevention, such as excreta, secreta, blood and its components, tissue and tissue swabs, body parts, and specimens in transport media (e.g. , transwabs, culture media, and blood culture bottles). (See § 173.134(a)(3) and (a)(4).)

Care should be taken, however, when transporting materials on the same vehicle as RMW. The surfaces of packages containing non-contaminated items may become contaminated by direct or indirect contact (e.g., transfer or aerosolization) with pathogenic materials emitted from or on the surface of RMW packages, or their transport containers or transport vehicles. As a result, the clean items within the packages may inadvertently become contaminated when they come in contact with hands or tools used to open them. We recommend when such transportation occurs that shippers and carriers take steps to prevent the contamination of the outer surface of these packages.

I hope this satisfies your request.


Susan Gorsky

Regulations Officer

Office of Hazardous Materials Standards

173.134 (c), 173.197

Regulation Sections

Section Subject
173.134 Class 6, Division 6.2-Definitions and exceptions
173.197 Regulated medical waste