{"operation":"document","citation":"01-0214","title":"Honeywell — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-10-19","effective_on":null,"summary":"01-0214 response to Honeywell concerning 173.134.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0214.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0214.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0214","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010214.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington, D.C. 20590\n400 Seventh St., S.W.\nResearch and\nSpecial Programs\nAdministration\nOCT 19 2001\nMs. Barbara Konrad\nRef. No. 01-0214\nManager, Transportation Regulatory Affairs\nHoneywell\nP.O. Box 10957\nMorristown, NJ 07962-1057\nDear Ms. Konrad:\nThis is in response to your letter asking if the aerospace equipment contaminated with blood and\nhuman remains that your company collects from accident sites is regulated as an infectious\nsubstance under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You\nstated that your company has no reason to believe these items meet the definition in § 173.134\nfor an infectious substance.\nYour understanding is correct. Provided the aerospace equipment is not contaminated with other\nmaterial within the aircraft that meets the definition of an infectious substance, such as an\ninfectious substance package that has released its contents, it would not be regulated under the\nHMR.\nI hope this satisfies your request.\nSincerely,\nSour Guts\nTransportation Regulations Specialist\nOffice of Hazardous Materials Standard:\n010214\n-\n\n<<<PAGE 2>>>\n\nHoneywell\nHoneywell\nEdmonson\nP.O. Box 1057\nMorristown, NJ 07962-1057\n$173.134\nClassification\n01-0214\nAugust 14, 2001\nResearch and Special Programs Administration\nOffice of Hazardous Materials Standards (DHM-10)\nUS Department of Transportation\n400 Seventh Street SW\nWashington, DC 20590-0001\nSubject:\nInterpretation on Infectious Substance Classification\nEquipment Contaminated With Human Remains\nDear Sir or Madam:\nAfter an aircraft accident, Honeywell International teams are sometimes deployed to crash\nin the wreck. Some pieces of equipment are contaminated with blood and/or pieces of human\nsites to collect, package and ship Honeywell aerospace components and equipment damaged\nremains.\nWe believe these shipments do not meet the DOT definition of infectious substance (class\n6.2) under 49 CFR 173.134.\nWe base our conclusion on the following facts: (1) We have no reason to believe or suspect\nno reason to suspect that any of the blood or remains contained any agent listed in 42 CFR\nthat the blood or remains would cause any severe, disabling or fatal disease; (2) We have\nremains were certainly not prepared or manufactured in accordance with 9 CFR or 21 CFR\n72.3; (3) We are not shipping the blood / remains for diagnostic purposes; (4) The blood /\nregarding biologic or drug products; and (5) the blood / remains are not regulated medical\nwaste since they were not generated in any of the means listed in 49 CFR 173.134 (a)(4).\nbody part destined for interment or cremation) but believe these materials do not meet the\nWe do not see any specific exception for blood or human remains (other than for a corpse or\ndefinition of class 6.2 under DOT rules and the equipment contaminated with this material can\ntherefore be shipped \"not regulated\".\nPlease let us know if you concur with our assessment of this situation.\nSincerely,\nBahuakomal\nno 113-465.200\nBarbara Konrad\nManager, Transportation Regulatory Affairs","truncated":false,"body_characters":3063}