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Interpretation Response #11-0258 ([The University of North Carolina at Chapel Hill Department of Environment, Health & Safety] [Mr. Daniel Vick])

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

Interpretation Response Details

Response Publish Date:

Company Name: The University of North Carolina at Chapel Hill Department of Environment, Health & Safety

Individual Name: Mr. Daniel Vick

Location State: NC Country: US

View the Interpretation Document

Response text:

November 22, 2011

 

 

Mr. Daniel Vick

The University of North Carolina at Chapel Hill

Department of Environment, Health & Safety

1120 Estes Drive Ext., CB# 1650

Chapel Hill, North Carolina 27599

Ref. No. 11-0258

Dear Mr. Vick:

This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically, you ask for guidance in determining what technical name, if any, should be indicated on a shipping paper for a Category A infectious substance prepared in accordance with § 172.203(k) when the specific agent or pathogen is known.

Category A infections substances must be described on a shipping paper as "UN2814, Infectious substances, affecting humans, 6.2" or "UN2900, Infectious substances, affecting animals, 6.2", as appropriate. Because both § 172.101 Hazardous Materials Table (HMT) entries are identified by the letter "G" in column 1 of the HMT, the technical name must be entered on a shipping paper, in parentheses, in association with the basic description as prescribed in § 172.203(k).

Section 171.8 of the HMR defines a "technical name" as a recognized chemical name or microbiological name currently used in scientific and technical handbooks, journals, and texts. It also authorizes a generic description to be used as a technical name provided it readily identifies the general chemical or microbiological group of the material. Therefore, when the identity of the pathogen contained in an infectious substance is known, the technical name of the pathogen must be indicated in parentheses in association with the basic description on a shipping paper as prescribed in § 172.203(k). When the identity of the pathogen contained in an infectious substance is not known, but sufficient information is available to strongly suspect that it does contain a Category A infectious substance, § 172.203(k) of the HMR requires that the words ""suspected Category A infectious substance"" must be entered in parentheses in place of the technical name as part of the

proper shipping description on a shipping paper. Further, as specified in §§ 172.203(k) and 172.301(b), regardless of whether the pathogen of an infectious substance is known or

not known, the technical name of a Division 6.2 material should not be marked on the surface of its outer package.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division

172.203, 172.101, 171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.203 Additional description requirements