HighQ Testing LLC - Comments

As a third party certifying agency that focuses on the medical related areas of hazmat, we see a significant amount of packages that contain small tubes and bottles that carry potential infectious substances (category B primarily) and pathology related chemicals in small quantities. The volumes of these that are shipped on a daily basis can be huge when compared to other types of industries. The situation is that primaries pass 95 kPa tests when the mold is new. The problem is that these are not retested and millions or tens of millions of primaries are run under the assumption that they still meet the 95 kPa pressure diffential. The reality is that the mold has worn and the fit is not the same. We think that there needs to be language in 173.199 to indicate a 2 year retest on packaging and components. In many cases this is not sufficient due to volumes but it would greatly improve the situation in a market that is largely unaware of testing requirements.