{"operation":"document","citation":"03-0161","title":"ARUP Laboratories — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-08-11","effective_on":null,"summary":"03-0161 response to ARUP Laboratories concerning 173.196, 173.199.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0161.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0161.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0161","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030161.pdf","body":"<<>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nResearch and\nWashington, D.C. 20590\nSpecial Programs\nAdministration\nAUG 1 1 2003\nMr. Paul H. Brinton\nRef. No. 03-0161\nAssistant Vice President, Transportation and Logistics\nARUP Laboratories\n00 Chipeta Way\nSalt Lake City, Utah 8410\nDear Mr. Brinton:\nThis responds to your email of July 2, 2003, concerning the applicability the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) to the transportation of infectious substances.\nSpecifically, you ask about shipping paper and package labeling requirements for a shipment containing\nmultiple pathogens.\nAccording to your email, you ship specimens in containers that are placed inside plastic bags and then\nplaced within pressure vessels. Each specimen container may contain a different pathogen. Several\npressure vessels are then placed with temperature media inside a secondary packaging that consists of\na layer of fiberboard, a layer of urethane, and an additional layer of fiberboard that is coated with\nwaterproofing. The secondary packagings are then placed within an outside packaging. You provide\nan example of a shipping paper for a single package that contains three 5-ml tubes of Hepatitis C and\none 5-ml tube of Human immunodeficiency virus packed with 2.2 kg of dry ice. You ask how the\ndifferent hazardous materials contained in the package should be listed on the shipping paper.\nYour shipping paper entry for the infectious substances packed with dry ice should read as follows:\nProper Shipping Name\nUN or It\nPacking\nGroup\nSubsidiary Risk\nQuantity and type of packaging\naffecting humans (Hepatitis\nInfectious substance,\n6.2\nUN 2814\n20 ml\nimmunodeficiency virus)\nC, Human\nAND\nCarbon dioxide, solid\nUN 1845\nIll\n2.2kg\nPacked in 1 plastic box\n173.196173199\n030161\n\n<<>>\n\nAs an alternative, you may elect to list each pathogen separately. In that case, your shipping paper\nentry should read as follows:\nProper Stripping Name\nClass or\nDivision\nUN or ID No.\nPacking\nGroup\nSubsidiary Risk\nQuantity and type of packaging\naffecting humans (Hopatitis\nInfectious substance,\n6.2\nUN 2814\n15 ml\nc)\nAND\naffecting humans (Human\nInfectious substance,\n6.2\nUN 2814\n5 ml\nimmunodeficiency virus)\nAND\nCarbon dioxide, solid\nUN 1845\n22kg\nPacked in 1 plastic box\nWith your email, your provided a copy of the label that you propose to utilize to meet the package\nbe marked with the technical name of the hazardous material in parentheses in association with the\nmarking requirements of § 172.301 of the HMR. Paragraph (b) of § 172.301 requires a package to\nproper shipping name. On the label you provided, the technical names of the material are not listed in\nparentheses in association with the proper shipping name. To conform with § 172.301(b), the package\nmust be marked \"Infectious substance, affecting humans (Hepatitis C, Human immunodeficiency virus)\".\nI hope this information is helpful. If you have further questions, please do not hesitate to contact this\noffice.\nSincerely,\nEdward T. Mazzullo\nDirector, Office of Hazardous\nMaterials Standards\n...........\n\n<<>>\n\nGorsku\nGorsky, Susan\n€ /13/14\nSent:\nFrom:\nBrinton, Paul [brintoph@arupiab.com]\nSubject:\nTo:\nWednesday, July 02, 2003 12:09 PM\n$173.199\nGorsky, Susan\nInfectious Substance\nRE: DOT Infectious Substance/Diagnostic Specimen Transport Regulations\n03-0161\nOpen Pressure Vessel\nwith tube...\nBox with inner\nsections.jpg\nBox with opened\nrefrigerated s...\nDGD Form_filled\nout.jpg\nBox roady for\nshipping.jpg\nOpen Pressure\nVessel.jpg\nProper Shipping Name\nouter, and then\nOur packaging generally consists of a corrugated plastic\nthree possible configurations of inner containers, one for each temperature\nof specimen being shipped.\nfiberboard, a one inch layer of urethane,\nThe inner containers\nan additional layer of fiberboard,\nconsist of a layer of\nand that layer is coated with a waterproofing coating.\nmedium, either cold gel packs,\nor dry ice is interspersed with the pressure\nThe temperature\nvessels inside the inner container.\ncontainers, inside plastic bags and then inside the pressure vessels.\nThe specimens are generally in specimen\ncertification markings are on the plastic outer layer.\nfrom the outer plastic jacket was certified as a pack the entire\npackage was certified as a whole, the package is not considered an over\nI am including some pictures of our process.\nII not, I would be happy to print them and send them to you.\nI hope you can receive\nquestions, please call or contact me.\nbrief explanations as to what they show.\nIn addition, I would like to request\nIf you have\nlabeling of the shipping container with the names of the organisms.\nan official letter supporting our position on the\nformat of the DGD and the\nmay be able to give us.\nthat label the Proper Shipping Name (PSN) label.\nThank you for any help you\nPaul H. Brinton, MT (ASP)\nPresident, Transportation\n& Logistics\n500 Chipeta Way\nSalt Lake City, UT 84108\nbrintonph@aruplab.com \n(801) 584-5136\n-----Original Message-----\nSent: Monday, June\nSusan [mailto:Susan.Gorsky@rspa.dot.gov]\n'brintoph@aruplab.com'\nRegulations\nRE: DOT Infectious Substance/Diagnostic Specimen Transport\nPaul,\nI have consulted with several of my colleagues in the Hazmat Standards\nmultiple organisms in one\nThe answer to your question depends on how you package your\nbox, then you may list \"Infectious substance, affecting humans\" once on the\nIf by one shipment you mean a single\nshipping paper and list the different organisms in parentheses after the\nboxes, then you must separately list the contents of each box on the\nHowever, if your one shipment consists of several different\nshipping paper (thus, if five boxes, then five separate entries for\n\"Infectious substance, affecting humans\" followed by the technical name of\n\n<<>>\n\nthe specific organism after each entry). I hope this is helpful.\nSusan\nFrom: Brinton, Paul [mailto:brintoph@aruplab.com]\n•----Original Message-----\nTo: Gorsky, Susan\nSent: Wednesday, June 18, 2003 3:44\nRegulations\nSubject: RE: DOT Infectious Substance/Diagnostic Specimen Transport\nSusan, I am wrestling with an issue\nas to how a Dangerous Goods Declaration\nIt has been our procedure to list\n1 Son or procedure es is enforcise botan ame in\nLonge so Char forat, and and apcat he Treet o3 anement for dan\nthat, placed inside parentheses.\nthe opportunity for errors and extra forms to no good purpose.\nThis seems overly complex to us,\nme information to help alleviate this situation, or direct me to someone\nCan you give\nthat may be able to help ? Thank you very much.\nPaul H. Brinton, MI (ASCP)\nARUP Laboratories\nAssistant Vice\nPresident, Transportation & Logistics\nSalt Lake City, UT 84108\n500 Chipeta Way\nbrintonph@aruplab.com\n(801) 584-5136\n«›\nVessel with tubes. jpg>>\n«\nwith inner sections. jpg>>\nVessels wth gel packs.jpg>>\nshipping. jpg>>\n«Proper Shipping Name Label. ipq>>\n«Open Pressure Vessel.jpg>>\n«Pressure","truncated":false,"body_characters":7034}