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Interpretation Response #14-0208 ([Washington State Department of Health] [Mr. Chuck Talburt])

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

Interpretation Response Details

Response Publish Date:

Company Name: Washington State Department of Health

Individual Name: Mr. Chuck Talburt

Location State: WA Country: US

View the Interpretation Document

Response text:

March 26, 2015

Chuck Talburt
Washington State Department of Health
Public Health Laboratories
1610 NE 150th Street
Shoreline, WA 98155

Reference No. 14-0208

Dear Mr. Talburt:

This is in response to your October 29, 2014 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a courier, including a private vehicle or a taxi, transporting blood specimens to and from your facilities for testing for the presence of the Ebola virus. You expressed concern that the courier services currently used transport Category B infectious substances (Division 6.2) or excepted specimens, and that these materials may be subject to additional regulation under the HMR if they are potentially Category A infectious substances. You also ask if a courier transporting these specimens must be dedicated to the purpose of transporting the specimens and not transporting passengers or administrative material.

In accordance with HMR § 173.134(a)(1)(i), blood specimens known or reasonably expected to contain the Ebola virus, or other infectious substance in a form capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals, would be classified as a Category A infectious substance. The offeror may rely on the judgment of a responsible medical expert to determine whether the specimens being shipped are reasonably expected to contain a Category A material.

Specimens classified as Category A infectious substances are subject to all applicable provisions of the HMR for these materials (such as shipping papers, marking, labeling, emergency response information, and training) and must be packaged in accordance with the requirements of § 173.196. Category A infectious substances transported in full compliance with the HMR are not restricted to transport by private or contract carrier in a dedicated motor vehicle. However, in accordance with § 177.870(b) such hazardous materials may not be transported on a motor vehicle carrying passengers for hire unless no other practical means of transportation is available. Please note the relief from the HMR that you mentioned concerning Division 6.2 materials transported by private or contract carrier in a motor vehicle used exclusively to transport such materials is prescribed in § 173.134(b)(10) and applies to Category B infectious substances only.

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.



Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

173.134(a)(1)(i), 177.870(b), 173.196. 173.134(b)(10)

Regulation Sections

Section Subject
173.134 Class 6, Division 6.2-Definitions and exceptions