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Interpretation Response #08-0252 ([Federal Reserve System Cash Product Office Federal Reserve Bank of San Francisco, Los Angeles Branch] [Mr. Alex Torres])

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

Interpretation Response Details

Response Publish Date:

Company Name: Federal Reserve System Cash Product Office Federal Reserve Bank of San Francisco, Los Angeles Branch

Individual Name: Mr. Alex Torres

Location State: CA Country: US

View the Interpretation Document

Response text:

December 22, 2008






Mr. Alex Torres

Project Analyst, National Cash Operations

& Business Continuity

Federal Reserve System Cash Product Office

Federal Reserve Bank of San Francisco,

Los Angeles Branch

950 S. Grand Avenue

Los Angeles, CA 90015

Ref. No.: 08-0252

Dear Mr. Torres:

This responds to your letter regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of "contaminated currency". Contaminated currency is typically currency exposed to human blood, mildew, and dye pack ( pepper spray elements). You ask for written confirmation of your understanding that the transportation of "contaminated currency" is not subject to federal and/or state regulation.

Your understanding is correct. Currency collected from banks that has been contaminated by a variety of substances (e.g., blood, body fluids, sewage, dye pack chemical, etc.) is not regulated as a hazardous material (e.g., infectious substance) under the HMR. 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. Based on the information you provided, the soiled currency does not meet the definition of an infectious substance in § 173.134 because there is no reason to know or strongly suspect the currency contains an infectious substance.

Further, a government entity, such as the Federal Reserve Bank, preparing packages of "contaminated currency" meeting the definition of an infectious substance for exclusive transportation by the Federal Reserve Bank for non-commercial purposes, using Federal



Reserve Bank drivers and Federal Reserve Bank controlled vehicles for transport is not

subject to the HMR. However, if the purpose is commercial, or if the government agency offers hazardous materials for transportation to commercial carriers, then the HMR apply.

I hope this information is helpful. If we can be of further assistance, please contact us.

Sincerely,

Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

171.1

Regulation Sections

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