{"operation":"document","citation":"03-0139","title":"Brink's U.S. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-06-24","effective_on":null,"summary":"03-0139 response to Brink's U.S. concerning 173.134.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0139.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0139.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0139","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030139.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nJ.S. Departmeni\nJUN 24 2003\n400 Seventh St., S.W.\n• Washington, D.C. 20590\ndministratior\nMr. Stan Turbyfill\nDirector of Safety\nRef. No: 03-0139\nBrink's U.S.\n555 Dividend Drive, Suite 100\nCoppell, Texas 75019-4959\nDear Mr. Turbyfill:\nThis is in response to your June 2, 2003 letter asking whether currency collected from banks that\nhas been contaminated by a variety of substances (e.g., blood, body fluids, sewage, dye pack\nchemical, etc.) would be regulated as an infectious substance under the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). You state that your company has no reason to\nbelieve this currency, which is transported to the Federal Reserve for destruction, meet the\ndefinition in § 173.134 for an infectious substance.\nAs you state, the HMR define an \"infectious substance\" in § 173.134 as a material known to\ncontain or suspected of containing a pathogen that has the potential to cause disease in humans or\nanimals. Therefore, based on the information you provided, the soiled currency do not meet the\ndefinition of an infectious substance in § 173.134 because there is no reason to know or strongly\nsuspect the currency contain an infectious substance.\nI hope this satisfies your request.\nSincerely,\nHother. Mitchel\nHattie L. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n173.134\n030139\n\n<<<PAGE 2>>>\n\nBetts\n5173.134\nInfectiousdubtances\nIIIIBRINKS\nBrink's U.S.\n03-0139\nA Division of Brink's, Incorporated\nSuite 100\n555 Dividend Drive\nTel: (469) 549-6033\nCoppell, Texas 75019-4959\nStan Turbyfill\nFax: (469) 549-6232\nDirector of Safety\nA Subsidiary of The Pittston Company\nJune 2, 2003\nSubject:\nInterpretation on Contaminated Currency and Infectious Substance Classification\nCurrency Contaminated with Human Blood or Body Fluids\nDear Sir or Madam:\nOn occasion banks receive currency that has been mutilated or contaminated by a variety of substances. The most\nchemicals or other substances that make the currency unsuitable for circulation. The bank personnel usually remove the\ncommon contaminants are blood, body fluids, sewage, and dye pack chemical, while less frequent items are water, mold\n\"contaminated currency\" and double bag it in heavy-duty, tamper-resistant, clear plastic security bags. The bags in turn are\nWe believe these shipments do not meet the definition of infectious substance (class 6.2) under 49 CFR 173.134.\nWe base our conclusion on the following facts:\n• We have no reason to believe or suspect that the blood or bodily fluids or other contaminants would cause any severe,\n• We have no reason to suspect that any of the blood or contaminants contained any agent listed in 42 CFR 72.3\ndisabling or fatal disease;\n• The blood/fluids were not prepared or manufactured in accordance with 9 CFR or 21 CFR regarding biologic or drug\n• We are not shipping the contaminated currency for diagnostic purposes;\n• The contaminated currency appears to meet conditions consistent with other exceptions of Division 6.2 materials\n• The potential exposure is minimal due to the airtight, tamper resistant sealed double-bag packaging.\ngranted per 173.134 (b).\nFurthermore, We believe that it is in the interest of public safety for \"Contaminated Currency\" to be shipped under armed\nescort to prevent theft and reintroduction into circulation.\nPlease let us know if you concur with our assessment of this situation.\nHe Tubje\nStan Turbyfill\nDirector of Safety","truncated":false,"body_characters":3472}