Honeywell — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. Research and Special Programs Administration OCT 19 2001 Ms. Barbara Konrad Ref. No. 01-0214 Manager, Transportation Regulatory Affairs Honeywell P.O. Box 10957 Morristown, NJ 07962-1057 Dear Ms. Konrad: This is in response to your letter asking if the aerospace equipment contaminated with blood and human remains that your company collects from accident sites is regulated as an infectious substance under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You stated that your company has no reason to believe these items meet the definition in § 173.134 for an infectious substance. Your understanding is correct. Provided the aerospace equipment is not contaminated with other material within the aircraft that meets the definition of an infectious substance, such as an infectious substance package that has released its contents, it would not be regulated under the HMR. I hope this satisfies your request. Sincerely, Sour Guts Transportation Regulations Specialist Office of Hazardous Materials Standard: 010214 -#

Page 2Honeywell Honeywell Edmonson P.O. Box 1057 Morristown, NJ 07962-1057 $173.134 Classification 01-0214 August 14, 2001 Research and Special Programs Administration Office of Hazardous Materials Standards (DHM-10) US Department of Transportation 400 Seventh Street SW Washington, DC 20590-0001 Subject: Interpretation on Infectious Substance Classification Equipment Contaminated With Human Remains Dear Sir or Madam: After an aircraft accident, Honeywell International teams are sometimes deployed to crash in the wreck. Some pieces of equipment are contaminated with blood and/or pieces of human sites to collect, package and ship Honeywell aerospace components and equipment damaged remains. We believe these shipments do not meet the DOT definition of infectious substance (class 6.2) under 49 CFR 173.134. We base our conclusion on the following facts: (1) We have no reason to believe or suspect no reason to suspect that any of the blood or remains contained any agent listed in 42 CFR that the blood or remains would cause any severe, disabling or fatal disease; (2) We have remains were certainly not prepared or manufactured in accordance with 9 CFR or 21 CFR 72.3; (3) We are not shipping the blood / remains for diagnostic purposes; (4) The blood / regarding biologic or drug products; and (5) the blood / remains are not regulated medical waste since they were not generated in any of the means listed in 49 CFR 173.134 (a)(4). body part destined for interment or cremation) but believe these materials do not meet the We do not see any specific exception for blood or human remains (other than for a corpse or definition of class 6.2 under DOT rules and the equipment contaminated with this material can therefore be shipped "not regulated". Please let us know if you concur with our assessment of this situation. Sincerely, Bahuakomal no 113-465.200 Barbara Konrad Manager, Transportation Regulatory Affairs#