Interpretation Response #08-0158 ([Toppenish Community Hospital] [Carolyn Arms, MT(ASCP)])

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

Interpretation Response Details

Response Publish Date: 07/15/2009

Company Name: Toppenish Community Hospital

Individual Name: Carolyn Arms, MT(ASCP)

Location State: WA Country: US

View the Interpretation Document

Response text:

July 15, 2009

Carolyn Arms, MT(ASCP)

Director of Laboratory

Yakima Regional Medical & Cardiac Center

Toppenish Community Hospital

110 South 9th Avenue

Yakima, WA 98902

Reference No. 08-0158

Dear Ms. Arms:

This is in response to your e-mail requesting clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of infectious substances. Specifically, you ask if a Petri dish containing a Category B infectious substance and covered with a lid that is not leak- or sift-proof meets the definition of a primary receptacle (packaging) under § 173.199 of the HMR. You also ask if the packaging would be considered leak- or sift-proof if it is placed inside another container that does meet this requirement, such as a sealed polyethylene bag. We apologize for the delay in responding and any inconvenience this may have caused.

A Petri dish covered with a lid that is not leak- or sift-proof does not meet the definition of a primary receptacle under § 173.199 of the HMR. The HMR require primary receptacles for Category B infectious substances to be leak-proof for liquids and sift-proof for solids. Often these types of closure can be achieved by securely attaching a lid to a packaging with wire, tape, or any other positive means, such as a friction closure. See § 173.199(b)(1) and (c)(1). Alternatively, to meet this requirement, a petri dish may be placed in a second container, such as a sealed polyethylene bag, that is leak-proof if the dish contains liquids and sift-proof if it contains solids. In this case, the polyethylene bag is the primary receptacle for purposes of the triple packaging requirement in § 173.199. It is the opinion of this Office that placing the Petri dish within the polyethylene bag in a manner that secures the lid to the dish while the packaging is in transportation may facilitate the successful performance of this packaging. Primary receptacles must be packed in a secondary packaging in a manner that ensures the primary receptacles cannot break, be punctured, or leak their contents under normal transportation conditions. The secondary packaging must be secured in a rigid outer packaging with cushioning material that must not become impaired or impair the performance of the outer packaging if exposure to the packaging"s contents occurs. Further, the completed



package must be designed, constructed, maintained, filled, its contents limited, and each container in the packaging closed so that under normal transportation conditions the completed package will not permit any release of hazardous material into the environment. See § 173.199(a)(2), (a)(3), and (a)(4).

I hope this satisfies your request.

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.199

Regulation Sections