The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in an October 15th interpretive letter the application of the federal Hazardous Materials Regulations (“HMR”) to transportation of sharps containers in wheeled racks. See Reference No. 25-0165.
PHMSA was responding to a December 29, 2025 inquiry from Scopelitis, Gavin, Light, Hanson & Feary, P.C (“SGLHF”) regarding the transportation of sharps containers in wheeled racks.
SGLHF indicated that compliance with the “full rows” language in § 173.134(c)(2)(x) may require carriers to place empty containers in open spaces to prevent shifting. A desire to install a moveable bracket to define and secure the partial rows was described.
Therefore, the question posed was whether:
… a wheeled rack equipped with a “moveable bracket” to secure sharps containers satisfies the requirements of § 173.134(c)(2)(x), even if the rack does not contain a full row of containers spanning the entire length of the cart.
PHMSA responds in the affirmative, stating that the intent of the “full rows” language in § 173.134(c)(2)(x) is to ensure sharps containers are stowed securely, to prevent shifting or tipping during transportation. The agency further indicates that based on the information and photograph provided, the moveable bracket may satisfy the relevant statute, provided it firmly secures the partial row, effectively creating a “full row.” The bracket must provide equal or greater strength to a full row of containers. Finally, no shelf may exceed the manufacturer’s recommended load capacity, and the wheeled rack must be securely held in place on the motor vehicle
A copy of the interpretive letter can be found here.
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