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Interpretation Response #09-0299 ([SeraCare Life Sciences] [Mr. Colin Leavitt, Jr.])

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

Interpretation Response Details

Response Publish Date:

Company Name: SeraCare Life Sciences

Individual Name: Mr. Colin Leavitt, Jr.

Location State: MA Country: US

View the Interpretation Document

Response text:

February 3, 2010




Mr. Colin Leavitt Jr.

SeraCare Life Sciences

25 Birch Street

Milford, MA 01757

Ref. No. 09-0299

Dear Mr. Leavitt Jr.,

This responds to your December 8, 2009 email regarding the transportation of small quantities under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether materials transported by your company may be shipped as excepted quantities and you request clarification of closure requirements for inner packagings used for excepted quantities.

In your letter, you state that your company produces biological panels containing 4 ml capacity vials filled with a mixture of methanol (2.4 ml) and human blood and that you plan to ship the material by air. You ask whether you may ship this mixture of material as excepted quantities. Additionally, with regard to closure requirements for inner packagings, you ask whether a screw cap with an o-ring seal conforms to the requirements to use a positive means of closure for inner packagings.

Assuming the mixture meets the definition of a Class 3 flammable liquid material and the human blood does not meet the definition of a Division 6.2 infectious substance, you are correct that your company may elect to transport the material by air using the exceptions for excepted quantities provided in § 173.4a. Regarding the closure requirements for inner packagings, a screw cap with an o-ring seal does not provide a positive means to ensure that the screw cap will be held in place. In accordance with § 173.4a(e)(2), a removable closure must be held securely in place with wire, tape, or other positive means (e.g., shrink-wrap).

Note that the International Air Transport Association's standards do not have official standing under the HMR. When transporting hazardous material by air, you must transport in accordance with the HMR or alternative regulations authorized for use by the HMR in § 171.22 such as the

International Civil Aviation Organization"s Technical Instructions for the Safe Transport of Dangerous Goods by Air.

I hope this information is helpful. If you have further questions, please contact this Office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

173.4a, 171.22

Regulation Sections

Section Subject
173.4a Excepted quantities