University of Hawaii at Manoa — Hazardous Materials Safety Interpretation

Page 1- U.S. Department 400 Seventh St., S.W. of Transportation Washington, D.C. 20590 OCT 1 3 2000 Ms. Julie Coughlin Ref. No. 00-0240 University of Hawaii at Manoa St. John 307 3190 Maile Way Honolulu, HI 96822 Dear Ms. Coughlin: This is in response to your August 25, 2000 letter requesting clarification of shipments of diagnostic samples frozen with dry ice under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). For shipments by aircraft, Carbon dioxide, solid or Dry ice, UN1845, is excepted from the HMR when used as a refrigerant for the contents of a package if in quantities less than 2.3 kg of dry ice per package, provided it is packed according to § 173.217. This section requires the packaging to be vented and to meet the general packaging requirements of Part 173 Subpart B. In addition, the packai mia beat ed with the nag of the content bein cold bedt agat or borde or an (§ 175.10(a)(13)(1)). For example, an air shipment of fruit samples refrigerated by 2 kg of dry ice is not subject to any other requirement of the HMR if the packaging is designed and constructed to permit the release of carbon dioxide gas, meets the general packaging requirements of Part 173, and you mark the package with the words, "fruit", "2 kg" and "Dry Ice." I hope this information is helpful. If you have further questions, please do not hesitate to contact this Office. Sincerely, Ohmm hom Filio Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.217 000240 :#

Page 2University of Hawaii at Manoa Nelson $ 113.211 (e) August 25, 2000 Packaging Mr. Edward Nazzullo 00-0240 Director, Office of Hazardous Materials Standards USDOT/RSPA (DHM-10) 400 Seventh Street SW Washington, DC 20590 Dear Mr. Nazzullo, I would like to request a letter of interpretation regarding a specific packaging exemption listed in the 49 CFR, Part 173.217. I plan to ship frozen experimental samples packed in dry ice, using Federal Express air transportation. The dry ice is necessary to maintain the frozen integrity of the samples during transit. The experimental samples are frozen, untreated and pesticide-treated agricultural commodities (i.e., papaya, pineapple, green onion, etc.). The samples are not hazardous materials, but the dry ice that I plan to add to the package is a hazardous material (Part 172.101, Carbon Dioxide, Solid or Dry Ice, UN1845). The samples will be shipped to a chemistry laboratory for residue analysis. The residue chemistry data is used to support a pesticide tolerance. I would like some clarification as to whether my samples fall under the category of: "material being refrigerated is used for diagnostic or treatment purposes (e.g., frozen medical specimens)." (from Part 173.217, paragraph (e)). I want to make sure that these diagnostic samples fit the description listed in paragraph (e), and that it's OK to use this exemption for my shipments. Please call if you have any questions. Sincerely, Qui Confla Research Associate, Univ. of Hawaii Phone: (808) 956-2003 # FAX: (808) 956-9675 AN EQUAL OPPORTUNITY EMPLOYER#