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Interpretation Response #20-0062

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

Interpretation Response Details

Response Publish Date:

Company Name: Daniels Training Services, Inc.

Individual Name: Daniel Stoehr

Location State: IL Country: US

View the Interpretation Document

Response text:

March 9, 2021

Mr. Daniel Stoehr
Daniels Training Services, Inc.
P.O. Box 2032
Freeport, IL  61032

Reference No. 20-0062

Dear Mr. Stoehr:

This is in response to your August 5, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transporting COVID-19 diagnostic samples. Specifically, you ask whether the "Safety Advisory Notice for the Transportation of COVID-19 Diagnostic Samples" issued on June 19, 2020, by the Pipeline and Hazardous Materials Safety Administration (PHMSA) prohibits a person from offering for transportation in commerce a COVID-19 diagnostic sample (e.g., nasal swabs, vials of sputum, and other related items) as a Category B infectious substance (Division 6.2) in conformance with the provisions specified in § 173.134(b)(10) of the HMR.

The answer is no. As provided by § 173.134(b)(10), a Division 6.2 material—other than a Category A infectious substance—is not subject to the requirements of the HMR as a Division 6.2 material when contained in a patient sample being transported for research, diagnosis, investigational activities, or disease treatment or prevention, or a biological product, when such materials are transported by a private or contract carrier in a motor vehicle used exclusively to transport such materials.

I hope this information is helpful. Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


Regulation Sections

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