Interpretation Response #08-0274 ([Alcor Life Extension Foundation] [Ms. Tanya Jones])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Alcor Life Extension Foundation
Individual Name: Ms. Tanya Jones
Location State: AZ Country: US
View the Interpretation Document
Response text:
December 11, 2008
Ms. Tanya Jones
Alcor Life Extension Foundation
7895 E. Acoma Drive, #110
Scottsdale, AZ 85260
Ref. No. 08-0274
Dear Ms. Jones:
This responds to your October 20, 2008 email and subsequent telephone conversations with a member of my staff requesting clarification of the transport of corpses on dry ice under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
You indicate that occasionally due to time constraints, morticians will ship by aircraft corpses on dry ice in quantities of less than five pounds in accordance with § 173.217. You point out this quantity of dry ice is not satisfactory for something the size of a human body. You request guidance for air shipment of corpses using adequate amounts of dry ice in specially designed containers (i.e, a Ziegler container) not exceeding 200 kg capacity.
When transported by aircraft, non-bulk quantities of dry ice used as a refrigerant must be transported in accordance with § 173.217. Dry ice in quantities greater than 5.5 pounds per package must be shipped as follows:
" Dry ice must be packed in packagings designed and constructed to permit the release of gas to prevent a buildup of pressure that could rupture the packagings.
" Packagings must conform to the general packaging requirements of Subpart B of Part 173 but are not required to conform to specification packaging requirements in Part 178.
" In addition to the proper shipping name and ID number marking requirements (e.g., "Dry ice," UN1845), the net mass of the dry ice must be marked on the package.
" The shipper must make arrangements with the operator of the air carrier for each shipment.
" The shipper must comply with shipping paper requirements; or must provide an alternative written document containing the following information: proper shipping name (Dry ice or Carbon dioxide, solid); Class 9; UN1845; the number of packages; and the net quantity of dry ice in each package. A shipper providing an alternative written document with the above information is not subject to the emergency response information requirements in Subpart G of Part 172.
In addition to the listed requirements, the packaging must be labeled with a Class 9 label and employees performing a hazmat function associated with the transport of the dry ice are subject to the HMR and must be trained in accordance with Subpart H of Part 172.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
Charles Betts,
Chief, Standards Development
Office of Hazardous Materials Standards
173.217