From: Edward Movitz <movitz**At_Symbol_Here**OLEMISS.EDU>
Subject: Re: [DCHAS-L] Manifest retention
Date: Fri, 20 Oct 2017 18:58:11 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: CY1PR18MB0346B67E6C78FCEB58C40249D1430**At_Symbol_Here**CY1PR18MB0346.namprd18.prod.outlook.com
In-Reply-To


The question was about medical waste. This is not about a Hazardous waste.  


Infectious Medical waste 6.2 is not the same as frozen cats and rats. These have no DOT code, and are not a regulated hazardous material. 


=A7 173.134 Class 6, Division 6.2 - Definitions and exceptions.


(c)Exceptions for regulated medical waste. The following provisions apply to the transportation of regulated medical waste:

(1) A regulated medical waste transported by a private or contract carrier is excepted from -

(i) The requirement for an "INFECTIOUS SUBSTANCE" label if the outer packaging is marked with a "BIOHAZARD" marking in accordance with 29 CFR 1910.1030; and

(ii) The specific packaging requirements of =A7 173.197, if packaged in a rigid non-bulk packaging conforming to the general packaging requirements of =A7=A7 173.24 and 173.24a and packaging requirements specified in 29 CFR 1910.1030, provided the material does not include a waste concentrated stock culture of an infectious substance. Sharps containers must be securely closed to prevent leaks or punctures.

(2) The following materials may be offered for transportation and transported as a regulated medical waste when packaged in a rigid non-bulk packaging conforming to the general packaging requirements of =A7=A7 173.24 and 173.24a and packaging requirements specified in 29 CFR 1910.1030 and transported by a private or contract carrier in a vehicle used exclusively to transport regulated medical waste:

(i) Waste stock or culture of a Category B infectious substance;

(ii) Plant and animal waste regulated by the Animal and Plant Health Inspection Service (APHIS);

(iii) Waste pharmaceutical materials;

(iv) Laboratory and recyclable wastes;

(v) Infectious substances that have been treated to eliminate or neutralize pathogens;

(vi) Forensic materials being transported for final destruction;

(vii) Rejected or recalled health care products;

(viii) Documents intended for destruction in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) requirements;

(ix) Medical or clinical equipment and laboratory products provided they are properly packaged and secured against exposure or contamination; or

(x) Sharps in sharp containers provided the containers are securely closed to prevent leaks or punctures; do not exceed 18 gallons capacity; registered under the Medical Device Regulations of FDA; made of puncture resistant plastic that meets ASTM Standard F2132-01, Standard Specification for Puncture Resistance of Materials Used in Containers for Discarded Medical Needles and Other Sharps; and are securely fitted into wheeled racks that hold them in an upright position. The wheeled racks must contain full rows of sharps containers secured in place by a moveable bar; and must be securely held in place on the motor vehicle by straps or load bars during transportation. No shelf in any wheeled rack may exceed the manufacturer's recommended load capacity.

Ed



 



 

Edward M. Movitz

Research & Environmental Compliance Officer / FSO

The University of Mississippi 

Laboratory Services

100 Health and Safety Building

P.O. Box 1848

University, MS 38677-1848

U.S.A.

O:+1-662-915-5433 | F: 662-915-5480

movitz**At_Symbol_Here**olemiss.edu |  www.olemiss.edu |  Laboratory Services Web Site

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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Battles, Paul <pmb024**At_Symbol_Here**SHSU.EDU>
Sent: Friday, October 20, 2017 1:42 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Manifest retention
 

Ok, so 40 CFR 262.23 pertains to biological/medical waste manifest as well? Not just a hazardous chemical waste manifest.

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Dave Einolf
Sent: Friday, October 20, 2017 1:35 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Manifest retention

 

Ed:

 

Hope the University of Mississippi is in compliance!

 

3 YEARS

 

40 CFR 262.23(f)(4)  (Federal Requirement)

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Edward Movitz
Sent: Friday, October 20, 2017 11:17 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Manifest retention

 

The retention time is likely set by your State as there is no federal requirement for retention. 

 

I would suggest your organization save them forever.

Ed

 

 

 

Edward M. Movitz

Research & Environmental Compliance Officer / FSO

The University of Mississippi 

Laboratory Services

100 Health and Safety Building

P.O. Box 1848

University, MS 38677-1848

U.S.A.

O:+1-662-915-5433 | F: 662-915-5480

movitz**At_Symbol_Here**olemiss.edu |  www.olemiss.edu |  Laboratory Services Web Site

Please Consider the Environment before printing this Email.

Confidentiality Note: The information contained in this e-mail and/or document(s) attached is for the exclusive use of the individual named above and may contain confidential and privileged information. If you are not the intended recipient, please immediately delete this message and all copies of it from your system. You are hereby notified that you are strictly prohibited from reading, photocopying, distributing or otherwise using this e-mail or its contents in any way. If you have received this transmission in error, please notify the sender immediately.

 


From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Battles, Paul <pmb024**At_Symbol_Here**SHSU.EDU>
Sent: Friday, October 20, 2017 11:24 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] Manifest retention

 

Hello all,

 

What is the retention time for biohazardous/medical waste manifest?

 

Thank you,

 

Paul Battles

Science Labs Safety Coordinator

EHS & Risk Management

Sam Houston State University

816 17th Street

Box 2327

Huntsville, TX. 77301

936.294.2672

pmb024**At_Symbol_Here**shsu.edu

 

 

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