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Interpretation Response #07-0023 ([NM Scientific Lab] [Ms. Pamela Morden MT (ASCP), MPH])

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

Interpretation Response Details

Response Publish Date:

Company Name: NM Scientific Lab

Individual Name: Ms. Pamela Morden MT (ASCP), MPH

Location State: DC Country: US

View the Interpretation Document

Response text:

Mar 1, 2007

Ms. Pamela Morden MT (ASCP), MPH                                          Reference No. 07-0023

Laboratory Bioterrorism Readiness Coodinator

NM Scientific Lab

700 Comino de Salud NE

Albuquerque, NM 87196-4700

Dear Ms. Morden:

This is in response to your January 25, 2007 e-mail regarding the materials of trade exceptions (MOTS) under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that you receive potential pathogens (formerly belonging to risk group 2 and 3) that have been isolated from patients for further identification and testing. You ask whether a private courier service can use MOTS to transport non-Category A cultures that are intentionally propagated, but are not contained in human or animal samples.

The answer is no. Under § 173.6 of the HMR, the MOTS exception may be used o transport a Division 6.2 material, other than a Category A infectious substance, contained in human or animal samples (including, but not limited to, secreta, excreta, blood and its components, tissue and tissue fluids, and body parts) being transported for research, diagnosis, investigational activities, or disease treatment or prevention, or is a biological product or regulated medical waste.

Although your material is other than a Category A infectious substance, it is not contained in human or animal samples and, therefore, does not meet the requirements for the MOTS exception for Division 6.2 material found under § 173.6.

I hope this information is helpful.

Sincerely,

John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

173.6

Regulation Sections

Section Subject
173.6 Materials of trade exceptions