USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #03-0161 ([ARUP Laboratories] [Mr. Paul H. Brinton])

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

Interpretation Response Details

Response Publish Date:

Company Name: ARUP Laboratories

Individual Name: Mr. Paul H. Brinton

Location State: UT Country: US

View the Interpretation Document

Response text:

Aug 11 2003

 

Mr. Paul H. Brinton                Ref No. 03-0161
Assistant Vice President,
Transportation and Logistics

ARUP Laboratories
500 Chipeta Way
Salt Lake City, Utah 84108

Dear Mr. Brinton:

This responds to your email of July 2, 2003, concerning the applicability the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of infectious substances. Specifically, you ask about shipping paper and package labeling requirements for a shipment containing multiple pathogens.

According to your email, you ship specimens in containers that are placed inside plastic bags and then placed within pressure vessels. Each specimen container may contain a different pathogen. Several pressure vessels are then placed with temperature media inside a secondary packaging that consists of a layer of fiberboard, a layer of urethane, and an additional layer of fiberboard that is coated with waterproofing. The secondary packagings are then placed within an outside packaging. You provide an example of a shipping paper for a single package that contains three 5-ml tubes of Hepatitis C and one 5-ml tube of Human immunodeficiency virus packed with 2.2 kg of dry ice. You ask how the different hazardous materials contained in the package should be listed on the shipping paper.

Your shipping paper entry for the infectious substances packed with dry ice should read as follows:

Proper Shipping Name

Class or

UN or ID

Packing

Subsidiary Risk

Quantity and type of packaging

 

Division

No.

Group

 

 

Infectious substance,

6.2

UN 2814

 

 

20ml

affecting humans (Hepatitis

 

 

 

 

 

C,Human

 

 

 

 

 

immunodeficiency virus)

 

 

 

 

 

AND

 

 

 

 

 

Carbon dioxide, solid

9

UW 1845

III

 

2.2kg

 

 

 

 

 

Packed in 1 plastic box


As an alternative, you may elect to list each pathogen separately. In that case, your shipping paper entry should read as follows:

Proper Shipping Name

Class or

UN or ID No.

Packing

Subsidiary Risk

Quantity and type of packaging

 

Division

 

Group

 

 

Infectious substance,

6.2

UN 2814

 

 

15ml

affecting humans (Hepatitis

 

 

 

 

 

C)

 

 

 

 

 

AND

 

 

 

 

 

Infectious substance,

6.2

UN28l4

 

 

5ml

affecting humans (Human

 

 

 

 

 

immunodeficiency virus)

 

 

 

 

 

AND

 

 

 

 

 

Carbon dioxide, solid

9

UN 1845

ill

 

2.2kg

 

 

 

 

 

Packed in 1 plastic box

With your email, your provided a copy of the label that you propose to utilize to meet the package marking requirements of § 172.301 of the HMR. Paragraph (b) of § 172.301 requires a package to
be marked with the technical name of the hazardous material in parentheses in association with the proper shipping name. On the label you provided, the technical names of the material are not listed in parentheses in association with the proper shipping name. To conform with § 172.301 (b), the package must be marked "Infectious substance, affecting humans (Hepatitis C) Human immunodeficiency virus)).

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.

Sincerely,

 

Edward T. Mazzullo
Director, Office of Hazardous Materials Standards

173.196, 173.199

Regulation Sections

Section Subject
173.196 Category A infectious substances
173.199 Category B infectious substances