PHMSA Response Letter

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October 9, 2009

Ms. Kristela Ramos
The Jackson Laboratory-West
4910 Raley Boulevard
Sacramento, CA 95838

Ref. No. 09-0189

Dear Ms. Ramos:

This responds to your August 18, 2009 request for clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of live animals implanted with non-infectious tumor fragments or blood cells (stem cells). You indicate that the animals are used for research and ask whether they are subject to the HMR.

The answer is no. In accordance with § 173.134(b)(1), a material that does not contain an infectious substance or that is unlikely to cause disease in humans or animals is not subject to the requirements of the HMR applicable to the transportation of Division 6.2 materials.

I hope this answers your inquiry. If you need further assistance, do not hesitate to contact this Office.

Sincerely,

Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards

173.134(b)(1)