# Minigrip — Hazardous Materials Safety Interpretation

**Citation:** 13-0031  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2013-03-25

13-0031 response to Minigrip concerning 173.124, 173.134.

## Document text

<<<PAGE 1>>>

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
1200 New Jersey Ave, S.E.
Washington, D.C. 20590
MAR 2 5 2013
Mr. Ben Hellming
Mini grip
161 Kimball Bridge Road
Alpharetta, GA 30009
RefNo.: 13-0031
Dear Mr. Hellming:
This is a response to your January 25, 2013 email and subsequent telephone conversation
with a member of my staff requesting clarification of the Hazardous Materials Regulations
(HMR; 49 CFR Parts 1 00-185) with regard to general packaging requirements. Specifically,
you request confirmation that a packaging that your company has designed, which will not
contain hazardous materials, voluntarily complies with the venting requirements for
packaging specified in§ 173.24(g)(2).
In your email, you include a description of your packaging and pictures of the packaging
configuration. The packaging is considered a combination packaging and consists of a
primary leak-proof container to hold specimens, packed in a secondary bag that has been
fitted with a pressure release patch, which is further placed in a rigid outer container. The
package is marked with orientation arrows. Additionally, the bag has printed language
stating "do not cover pressure release patch." You indicate that the primary leak-proof cups
as well as the secondary bag have both been tested to withstand a 95 kPa internal pressure
test.
Based on the telephone conversation with my staff, these packages are meant to hold
specimens (e.g. blood and urine) that do not meet the definition of any hazard class,
including Division 6.2, Infectious Substance and are not subject to the l=IMR. While these
materials are not required to be shipped in conformance with the HMR, you intend for your
packaging to voluntarily comply with the general packaging requirements in§ 173.24(g)(2).
It should be noted that the venting requirement in§ 173.24(g)(2) is not a standalone
requirement. In order for a packaging to fully comply with the venting requirements of the
HMR, the packaging must conform to all requirements of§ 173.24(g).
The purpose of§ 173.24(g) is to allow for the venting of packages to reduce internal
pressure, which may develop by the evolution of gas from the contents. For all non-bulk
packaging venting is only permitted under the following conditions: (1) except for
shipments of cryogenic liquids as specified in§ 173.320(c) and of carbon dioxide, solid (dry

<<<PAGE 2>>>

ice), transportation by aircraft is not involved; (2) except as otherwise provided in this the
HMR, the evolved gases are not poisonous, likely to create a flammable mixture with air or
be an asphyxiant under normal conditions of transportation; and (3) the packaging is
designed so as to preclude an unintentional release of hazardous materials from the
receptacle.
It also be should be noted that if the packaging is intended to contain materials classified as
Division 6.2 (infectious substances), the requirements ofthe applicable packaging section
for the specific category of infectious substance(§§ 173.196, 173.197, and 173.199) must
also be met. Furthermore, § 173.134 provides exceptions from the HMR for potentially
infectious substances such as blood and urine.
I hope this information is helpful. If you have any more questions, please do not hesitate to
contact this office.
Sincerely,
Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division

<<<PAGE 3>>>

Drakeford, Carolyn (PHMSA)
From:
Sent:
To:
Subject:
Attachments:
JNFOCNTR (PHMSA)
Monday, January 28, 2013 1:45 PM
Drakeford, Carolyn (PHMSA)
FW: Jetter of Interpretation 173.24 G2
Minigrip Image Slide Show- 95kPA Bags- 25Jan13.wmv
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Hi Carolyn,
We received the following request for a formal letter of interpretation.
Thanks,
Victoria
From: Bennett Hellming [mailto:ben.hellming@minigrip.com]
Sent: Friday, January 25, 2013 4:25 PM
To: INFOCNTR (PHMSA)
Subject: letter of Interpretation 173.24 G2
To U.S. Department of Transportation:
We are launching a new 95 kPa specimen transport bag for air transportation of blood and laboratory samples and want
to be sure we understand the regulations with respect to our product and application.
We are a provider of liquid bio-hazard shipping bags used for blood vials and urine cups. Our package is a secondary
package- see attached picture. The primary container (blood vial and urine cup) is leak proof (and many times 95 kPa
rated). The primary container goes into our secondary package (used to tie patient paperwork to sample) and then goes
into a rigid outer container. Our shipping bag survives the 95 kPa internal pressure test by use of a pressure release patch
that allows the bag to vent when the bag expands and contracts during pressure changes during air transportation.
In the worst case scenario that the primary leak proof container leaks, out-gassing from the contents would be non-
flammable, non-poisonous and not an asphyxiate. The pressure release patch also contains an antimicrobial agent. Any
liquid leaking from the primary leak proof container would be contained in our absorbent system designed to absorb
more liquid then would be transported in the bag.
To prohibit blockage of pressure release patch during shipping, the outer rigid container has 'this side up arrows' to
ensure that the pressure release patch is oriented correctly and the bag has printed language stating 'do not cover
pressure release patch' during shipping.
Our bag passed a 95 kPa internal pressure test conducted by Southeast Testing & Enginee!ring, Lawrenceville, GA, a DOT
certified 3rd party certification lab.
We are requesting a DOT Letter of Interpretation that states that Minigrip 95 kPa bag is compliant with 49 CFR 173.24 G2
for our product.
Thank you,
Ben Hellming
General Manager
1

<<<PAGE 4>>>

P 770 422 4187 Ext. 111
c 770 335 3411
ben.hellming@minigrip.com
2

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2013/130031.pdf>
- Source ID: `phmsa`
- SHA-256: `8ed6cd1718742f6925b4a31d744f70cfd1e031e224a575fbfa7f0b5bc3ddafe8`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T07:49:06.720Z
- Document slug: `phmsa-interpretation-13-0031`

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