Interpretation Response #08-0252 ([Federal Reserve System Cash Product Office Federal Reserve Bank of San Francisco, Los Angeles Branch] [Mr. Alex Torres])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Federal Reserve System Cash Product Office Federal Reserve Bank of San Francisco, Los Angeles Branch
Individual Name: Mr. Alex Torres
Location State: CA Country: US
View the Interpretation Document
Response text:
December 22, 2008
Mr. Alex Torres
Project Analyst, National Cash Operations
& Business Continuity
Federal Reserve System Cash Product Office
Federal Reserve Bank of San Francisco,
Los Angeles Branch
950 S. Grand Avenue
Los Angeles, CA 90015
Ref. No.: 08-0252
Dear Mr. Torres:
This responds to your letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of "contaminated currency". Contaminated currency is typically currency exposed to human blood, mildew, and dye pack ( pepper spray elements). You ask for written confirmation of your understanding that the transportation of "contaminated currency" is not subject to federal and/or state regulation.
Your understanding is correct. Currency collected from banks that has been contaminated by a variety of substances (e.g., blood, body fluids, sewage, dye pack chemical, etc.) is not regulated as a hazardous material (e.g., infectious substance) under the HMR. The HMR define an "infectious substance" in § 173.134 as a material known to contain or suspected of containing a pathogen that has the potential to cause disease in humans or animals. Based on the information you provided, the soiled currency does not meet the definition of an infectious substance in § 173.134 because there is no reason to know or strongly suspect the currency contains an infectious substance.
Further, a government entity, such as the Federal Reserve Bank, preparing packages of "contaminated currency" meeting the definition of an infectious substance for exclusive transportation by the Federal Reserve Bank for non-commercial purposes, using Federal
Reserve Bank drivers and Federal Reserve Bank controlled vehicles for transport is not
subject to the HMR. However, if the purpose is commercial, or if the government agency offers hazardous materials for transportation to commercial carriers, then the HMR apply.
I hope this information is helpful. If we can be of further assistance, please contact us.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
171.1
Regulation Sections
| Section | Subject |
|---|---|
| 173.134 | Class 6, Division 6.2-Definitions and exceptions |