Interpretation Response #00-0082 ([Yellow Freight System, Inc.] [Mr. Robert A. Maberry, III])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 04/19/2000

Company Name: Yellow Freight System, Inc.

Individual Name: Mr. Robert A. Maberry, III

Location State: KS Country: US

View the Interpretation Document

Response text:

April 19, 2000

Mr. Robert A. Maberry, III                Ref.. No. 00-0082
Chemical Transportation Administrator
Yellow Freight System, Inc.
Post Office Box 7270
Overland Park, Kansas 66207

Dear Mr. Maberry:

This is in response to your letter dated March 21, 2000, requesting a clarification of the definition of "foodstuff"as used in §177.84 1 (e) of the Hazardous Materials Regulations (49 CFR; Parts 171-1 80).  Specifically, you ask whether medicines and solutions that are injected into the bloodstream by hypodermic needles or are intravenously injected into the body of humans and animals should be included in the definition of foodstuff under §177.841(e).

You state that the medicines and solutions referenced above should be included in a revised definition of foodstuff by RSPA because "contamination of this type of product by a poison would have the same end result as-a product consumed or ingested would have." RSPA defines foodstuff to mean food, feed, grain, oral medicines, or any edible material intended for consumption by humans or animals.

If you believe that the definition of foodstuff in §177.841(e) of the HMR should be amended to include medicines and solutions that are injected into the bloodstream of humans and animals, you may file a petition for a rule change to the Associate Administrator for Hazardous Materials Safety in accordance with §106.31 of the HMR.

I hope this answers your inquiry.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

177.841

Regulation Sections