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Interpretation Response #03-0139 ([Brink's U.S.] [Mr. Stan Turbyfill])

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

Interpretation Response Details

Response Publish Date:

Company Name: Brink's U.S.

Individual Name: Mr. Stan Turbyfill

Location State: TX Country: US

View the Interpretation Document

Response text:

Jun 24, 2003


Mr. Stan Turbyfill                Reference No. 03-0139
Director of Safety
Brink's U.S.
555 Dividend Drive, Suite 100
Coppell, Texas 75019-4959

Dear Mr. Turbyfill:

This is in response to your June 2, 2003 letter asking whether currency collected from banks that has been contaminated by a variety of substances (e.g., blood, body fluids, sewage, dye pack chemical, etc.) would be regulated as an infectious substance under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that your company has no reason to believe this currency, which is transported to the Federal Reserve for destruction, meet the definition in § 173.134 for an infectious substance.

As you state, 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. Therefore, based on the information you provided, the soiled currency do not meet the definition of an infectious substance in § 173.134 because there is no reason to know or strongly suspect the currency contain an infectious substance.

I hope this satisfies your request.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
173.134 Class 6, Division 6.2-Definitions and exceptions