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Interpretation Response #07-0088 ([SAIC-Frederick, Inc.] [Ms. Shawn K. Brown ])

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

Interpretation Response Details

Response Publish Date:

Company Name: SAIC-Frederick, Inc.

Individual Name: Ms. Shawn K. Brown 

Location State: MD Country: US

View the Interpretation Document

Response text:

Jul 17, 2007

Ms. Shawn K. Brown                 Reference No. 07-0088

SAIC-Frederick, Inc.

1050 Boyles Street

Frederick, MD 21702

Dear Ms. Brown:

This responds to your April 26, 2007 letter requesting clarification on packaging used for shipment of "UN 3373, Biological Substance, Category B" and "UN 1845, Carbon dioxide, solid" (dry ice) using Packing Instruction 650 and 904 under the International Civil Aviation Organization (ICAO) Technical Instructions, as well as the Hazardous Materials Regulations (HMR), 49 CFR Parts 171-180. Specifically, you ask if the packaging system must be manufactured by the same vendor, or, if packaging components may be comprised of similar products manufactured by various vendors.

According to your letter, your shipment consists of infectious substances (HIV or HBV blood/serum/plasma) on dry ice refrigerant assigned to "UN 3373, Biological Substance, Category B" and "UN 1845, Carbon dioxide, solid" (dry ice), shipped under Packing Instructions 650 and 904 of the IATA Dangerous Goods Manual. The International Air Transport Association"s Dangerous Goods Division advised you that there is no specific requirement that all components of a packaging system be manufactured by the same vendor under the IATA guidance book. You were further advised to contact the DOT for additional clarification under the HMR. You ask if packaging components comprised of similar various vendor products are acceptable packaging under the HMR.

The answer is yes. "Infectious Substance, Category B" and "Carbon dioxide, solid" (dry ice) must be packaged in accordance with provisions in §173.199 of the HMR. Additionally, dry ice must also meet provisions in § 173.217. There is no requirement under the HMR for the packaging system for "Infectious Substance, Category B" to be manufactured by the same vendor. Therefore, packaging for this shipment is acceptable if it meets all requirements in § 173.199 and 173.217 of the HMR.

I hope this answers your inquiry.


John A. Gale

Chief, Standards Development 

Office of Hazardous Materials Standards

173.217, 173.199, 173.476

Regulation Sections

Section Subject
173.199 Category B infectious substances
173.217 Carbon dioxide, solid (dry ice)
173.476 Approval of special form Class 7 (radioactive) materials