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Interpretation Response #10-0179 ([Washington State Public Health Laboratories] [Mr. Chuck Talburt])

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

Interpretation Response Details

Response Publish Date:

Company Name: Washington State Public Health Laboratories

Individual Name: Mr. Chuck Talburt

Location State: WA Country: US

View the Interpretation Document

Response text:

December 17, 2010




Mr. Chuck Talburt

Laboratory Program Advisor

Washington State Public Health Laboratories

1610 NE 150th Street

Shoreline, WA 98155

Reference No. 10-0179

Dear Mr. Talburt:

This is in response to your e-mail to the Pipeline and Hazardous Materials Safety Administration"s (PHMSA"s) Hazardous Materials Information Center, and subsequent telephone conversation with a member of my staff. In your letter, you state most of the petri dishes your clients use are made from plastic and they would like to use these dishes to transport anthrax cultures, which are typically Division 6.2 (infectious) Category A materials. You ask if petri dishes with lids may be used as primary containers to transport these cultures by motor vehicle, railcar, or aircraft under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Under § 173.196, a packaging for a Division 6.2 material that is a Category A infectious substance must meet the performance test requirements prescribed in § 178.609 and be marked in conformance with § 178.503(f). A packaging for a Category A infectious substance is a triple packaging consisting of a leakproof primary receptacle, a leakproof secondary packaging, and rigid outer packaging of adequate strength for its capacity, mass, and intended use (see § 173.196(a)(3)). Provided the completed package meets the applicable design requirements prescribed in § 173.196 for an infectious substance packaging, and the package successfully passes the performance tests required in § 178.609, use of the petri dish as an inner packaging to transport Category A anthrax cultures would be acceptable. However, a petri dish"s lid is typically not designed to be watertight. Therefore, additional packaging materials may be needed to meet this condition. For example, the lid of the dish could be secured to its base with tape or parafilm and this packaging placed in a sealed polyethylene bag that is watertight. This primary packaging could then be placed in a secondary packaging and secured in a manner that

prevents any puncture, tear, or breakage of the packaging materials. Further, the performance tests in § 178.609 require the packaging to be dropped on its bottom, top, sides, and corner, and cold-conditioned and immersed in water with no leakage from the primary receptacle. Additional requirements in §§ 173.196 and 178.609 may also apply.

I hope this satisfies your request.


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

173.196, 178.609

Regulation Sections

Section Subject
173.196 Category A infectious substances
178.609 Test requirements for packagings for infectious substances