# Warrenton Regional Laboratory, Virginia Department of Agriculture and Consumer Services — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 02-0127
- **title:** Warrenton Regional Laboratory, Virginia Department of Agriculture and Consumer Services — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2002-05-08
- **effective on:** Not available
- **summary:** 02-0127 response to Warrenton Regional Laboratory, Virginia Department of Agriculture and Consumer Services concerning 171.8.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-02-0127
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020127.pdf
**body:**

<<<PAGE 1>>>

Washington, D.C. 20590
400 Seventh St., S.W.
Research and
pecial Program
dministratior
MAY
8 2002
Ref. No. 02-0127
Beth E. Henricson, Ph.D.
Microbiologist Supervisor
Warrenton Regional Laboratory, Virginia Department
of Agriculture and Consumer Services
272 Academy Hill Road
Warrenton, Virginia 20186
Dear Dr. Henricson:
This responds to your May 1, 2002 e-mailed request for clarification of the Hazardous Materials
Regulations (HMR; 49 CFR Parts 171-180) as they apply to shipments of infectious substances.
Specifically, you ask whether a shipper may use a generic description as a technical name for an
infectious substance in place of the specific name of the pathogen contained in the infectious substance.
As defined in § 171.8 of the HMR, "technical name" means a recognized chemical name or
microbiological name currently used in scientific and technical handbooks, journals, and texts. A
generic description is authorized for use as a technical name provided it readily identifies the general
chemical group or microbiological group. For example, an infectious substance that contains the
pathogen bacillus anthracis could be described on a shipping paper as "Infectious substance, affecting
humans (bacillus species), 6.2, UN 2814" since "bacillus" is the genus or group name for the micro-
organism. In accordance with § 171.8, generic microbiological descriptions such as "bacteria,"
"fungus," or "viral samples" may be used only for samples of infectious substances that are being
transported for laboratory proficiency testing. Note that the emergency response information that must
accompany a shipment of an infectious substance, in accordance with Subpart G of Part 172 of the
HMR, must be specific to the pathogen contained in the infectious substance. In the case of a shipment
of bacillus anthracis, the emergency response information must include specific information about the
health and safely risks, how to handle a spill, and preliminary first aid measures (sec § 172.602(a)).
I hope this information is helpful. If you have further questions, please do not hesitate to contact this
office.
Sincerely,
elena 4. Mazzile
Edward T. Mazzullo, Direct
Office of Hazardous Materials Standards
111.8
020127

<<<PAGE 2>>>

Page 2
cc:
Mr. Mike Hoysler
Dangerous Goods Administration and Safety
FED EX Express
3670 Hacks Cross Road
Building G 2nd Floor
Memphis, Tenn 38125

<<<PAGE 3>>>

Gorsky
8|71. 8
Definitions
1 May 2002
02-0127
DAvard Mazarious Materials Standards
400 7th Street SW
DHM 10
ATTN: Ms. Susan Gorsky
Washington, DC 20590
Dear Sir:
Laboratory Safety Committee hosted a teleconference with officials from DOT, USDA, AAVLD committee
On 29 March of this year, the Association of Veterinary Laboratory Diagnosticians (AAVLD)
members, and Fed Ex. AAVLD's members are primarily scientific directors and scientific supervisors of
biosecurity of 6.2 labeled packages that contain infectious agents of potential use in incidents of bio- or
state and federal regulatory and university veterinary diagnostic laboratories. Because of concern over
alter the labeling so the packages would not be targeted for theft of the organisms contained in them. DOT
agro-terrorism, government agencies receiving those packages from our regulatory laboratories wished to
of your office, determined that our request did not require an exception to existing regulations. Regulations
officials from the Research and Special Programs Division, Ms. Susan Hedgepeth, and Ms. Susan Gorsky
Affecting Humans and Animals-Bacterial Pathogen," rather than specifying that the package contained
were interpreted to allow a generic statement of pathogens contained, such as "Infectious Substance
"Bacillus anthracis", for example.
requested that they receive a written interpretation of the existing regulations from DOT to that effect,
I spoke with Mr. Mike Hoysler of Fed Ex again this weck, and the Fed Ex legal department has
allowing them to accept use of a generic statement in place of the technical name pathogen description. At
interpretation of the regulations to that effect to the appropriate Fed Ex personnel. Copies of the
the suggestion of Ms. Gorsky, I am writing this letter to ask if your office will provide a written
distributed to all AAVLD-associated laboratories. Thank you for your prompt attention to this matter.
interpretation of DOT regulations permitting generic labeling of 6.2 packages in these instances will be
Sincerely,
Microbiologist Supervisor
Warrenton Regional Animal Health Laboratory
Quality Assurance Coordinator
Virgin of Deparment SAgriculture and Consumer Services
FAX: 1-540-347-6404
Phone: 1-540-347-6385
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