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Interpretation Response #04-0034 ([University of California, Irvine] [Mr. Chris Younghans-Haug])

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

Interpretation Response Details

Response Publish Date:

Company Name: University of California, Irvine

Individual Name: Mr. Chris Younghans-Haug

Location State: CA Country: US

View the Interpretation Document

Response text:

Mar 9, 2004


Mr. Chris Younghans-Haug                Reference No. 04-0034
University of California, Irvine
4600 Bison Avenue
Irvine, CA 92697-2725

Dear Mr. Younghans-Haug:

This is in response to your letter asking whether human cells and human cell lines are regulated under the Hazardous Materials Regulations (HMR; 49 CFR, Parts 171-180), the International Civil Aviation Association (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air, and the International Air Transport Association (IATA) Dangerous Goods Regulations.  You state that the materials are being transported for research purposes and do not contain pathogens.  You also ask for clarification regarding the marking of packages and use of a shipper’s declaration if these materials are not subject to the regulations.

The HMR authorizes the use of the ICAO Technical Instructions with certain exceptions as an alternative to the HMR, but does not authorize the use of the IATA Dangerous Goods Regulations.  For questions regarding the use of the IATA Dangerous Goods Regulations, we suggest you contact the organization at 514/390-6770.

Human cells and human cell lines that do not meet the definition of Division; 6.2 materials are not regulated under the HMR or the ICAO Technical Instructions unless the materials meet the definition of another hazard class or are contained in packages with other materials that are subject to the regulations, such as formalin (Class 3) or carbon dioxide (Class 9).

You also ask whether these materials, if non-regulated, require a proper shipping name, UN number and hazard class to be marked on packages and whether such materials require a shipper’s declaration stating that the materials are hazardous.  Packages containing materials that are not subject to the regulations may not be marked, certified, or otherwise represented as a hazardous material when a hazardous material is not present (see § 171.2(f)(2)).

I hope this information is helpful.  Please contact this office if you have additional questions.



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


Regulation Sections

Section Subject
171.2 General requirements