Interpretation Response #11-0112 ([Midstate Air Freight and Logistics, Inc., DBA Callahan Air Expediters] [Mr. Jeremy K. Nantz])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Midstate Air Freight and Logistics, Inc., DBA Callahan Air Expediters
Individual Name: Mr. Jeremy K. Nantz
Country: US
View the Interpretation Document
Response text:
July 20, 2011
Mr. Jeremy K. Nantz
Vice President
Operations and Training
Midstate Air Freight and Logistics, Inc., DBA Callahan Air Expediters
Reference No. 11-0112
Dear Mr. Nantz:
This responds to your May 6, 2011 email requesting clarification of the marking requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you inquire as to the appropriate marking requirements for shipments of material used for diagnostic or treatment purposes that are refrigerated with dry ice. Your questions are paraphrased and answered as follows:
Q1. Must the packages be marked to indicate the specific material contained therein or does the UN3373 marking alone satisfy the requirements pertaining to materials transported for diagnostic or treatment purposes?
A1. Section 173.199(d)(2) requires that the package is marked with the wording "Carbon dioxide, solid" or "Dry ice" and an indication that the material being refrigerated is used for diagnostic treatment purposes. It provides the example "frozen medical specimens" as an acceptable marking. For this reason, the UN3373 marking would not satisfy the marking requirements for diagnostic or treatment purposes that are refrigerated with dry ice; rather, as you suggest, a marking to indicate the specific material contained therein is required.
Q2. Does the fact that the box is being shipped to or from a clinic or laboratory adequately indicate that the material being refrigerated is being transported for diagnostic or treatment purposes?
A2. No. See A1 above.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Ben Supko
Chief, Standards Development Branch
Standards and Rulemaking Division
173.199(d)(2)
Regulation Sections
| Section | Subject |
|---|---|
| 173.199 | Category B infectious substances |