Interpretation Response #08-0274R
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 Foudation
Individual Name: Tanya Jones
Location State: AZ Country: US
View the Interpretation Document
Response text:
May 31, 2018
Ms. Tanya Jones
Alcor Life Extension Foundation
7895 E. Acoma Drive, #110
Scottsdale, AZ 85260
Reference No. 08-0274R
Dear Ms. Jones:
This letter revises our December 11, 2008 response 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). The final paragraph has been revised to clarify the labeling requirements for dry ice. The other contents of the letter have not changed.
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, 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. The Hazardous Materials Table (§ 172.101) indicates "None" for the label code in column (6) for the UN1845 entry. Therefore, UN1845 has no labeling requirements under the HMR.
I hope this information is helpful. Please contact us if you require additional assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division