Interpretation Response #08-0276 ([PAML] [Ms. Marguerite Busch])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: PAML
Individual Name: Ms. Marguerite Busch
Location State: WA Country: US
View the Interpretation Document
Response text:
December 11, 2008
Ms. Marguerite Busch
PAML
Chief Compliance Officer
110 W. Cliff Avenue
Spokane, WA 99204
Ref. No. 08-0276
Dear Ms. Busch:
This responds to your October 30, 2008 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a petri dish covered with and sealed to a lid with watertight tape or parafilm that is placed in a leakproof plastic bag meets the criteria for a primary packaging under § 173.199 of the HMR.
The answer is yes. A primary or secondary Category B infectious substance (Division 6.2) packaging may consist of more than one packaging material or container provided the completed packaging and its components conform to the requirements prescribed in § 173.199 that apply to the materials they contain. In accordance with §173.199, the completed packaging must be a triple packaging consisting of a primary receptacle, a secondary packaging, and a rigid outer package. For liquid Category B infectious substances, both the primary and secondary packaging must be leakproof. For solid Category B infectious substances, both the primary and secondary packagings must be siftproof. In addition, a § 173.199 package must be capable of successfully passing the drop tests prescribed in paragraphs (d) and (h) of § 178.609 at a drop height of at least 1.2 meters (3.9 feet). Capability may be demonstrated using a number of methods, including actual previous handling and transportation experience, design specification, or, even though not required, performance testing. Also, please note that under certain transportation conditions the petri dish may meet the HMR"s definition of a sharp (see § 173.134(a)(6)). Care should be taken to ensure the dishes will not cut or otherwise damage the secondary or outer packaging.
I hope this answers your inquiry.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.199
Regulation Sections
| Section | Subject |
|---|---|
| 173.199 | Category B infectious substances |