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This letter is in response to your June 8, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Category B infectious substances. You ask if interpretation letter (Reference No. 09-0011) and the training requirements it describes for transporting Category B infectious substances in accordance with § 173.199 remain valid.
The answer is yes, interpretation letter (Reference No. 09-0011) remains valid. Further, based on a cursory review of the training module you provided, it is the opinion of this Office that the content sufficiently covers the provisions in § 173.199. Employees who are trained in and familiar with the requirements of § 173.199 are excepted from all other training requirements of the HMR when Category B infectious substances are offered for transportation or transported in commerce under the provisions of § 173.199. Please note, this letter does not act as certification of your training module nor does this Office certify training required by § 173.199(e).
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