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Interpretation Response #99-0009 ([New York State Department of Environmental Conservation] [Alan G. Woodard, PhD])

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

Interpretation Response Details

Response Publish Date:

Company Name: New York State Department of Environmental Conservation

Individual Name: Alan G. Woodard, PhD

Location State: NY Country: US

View the Interpretation Document

Response text:

MAR 3,1999


Alan G. Woodard, PhD                 Reference No. 99-0009
Regulated Medical Waste Program Supervisor
Division of Solid and Hazardous Materials
New York State Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233-7258

Dear Dr. Woodard:

This is in response to your electronic messages of October 8, 1998, and January 5, 1999, asking if couriers of "Regulated medical waste, 6.2, UN 3291, PG II" are subject to the Department of Transportation's Hazardous Materials Regulations HMR; 49 CFR Parts 171-180).  You stated one company, Health Care Waste Services, is proposing to use couriers to collect regulated medical waste (RMW) from doctor's offices.

The answer is yes.  Under § 171. 1 (a), intrastate and interstate shippers and carriers, including couriers, of hazardous materials, which includes certain RMW, are subject to the HMR.  Examples of waste materials that are excepted from regulation under the HMR are waste from households, and corpses or anatomical remains intended for cremation or interment.  See § 173.134(b)(1).

As you were informed by Ms. Eileen Mack of my staff, prior to October 1, 1997, the intrastate transportation of infectious substances (Division 6.2), including RMW, was not regulated under the HUR.  The scope of the HMR to include the intrastate transportation of these materials was expanded in final rules published under Docket HM-200 (January 8, 1997, 62 FR 1208; September 22, 1997, 62 FR 49560; February 18, 1998, 63 FR 8140).  Compliance with the final rule requirements was mandatory beginning October 1, 1998.

I hope this satisfies your request.  Should you have further questions, please contact this office.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions