SAIC-Frederick, Inc. — Hazardous Materials Safety Interpretation

Page 1Transportatic S. Departme Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safety Pipeline and Administration JUL 17 2007 SAIC-Frederick, Inc. Ms. Shawn K. Brown Ref. No. 07-0088 1050 Boyles Street Frederick, MD 21702 Dear Ms. Brown: This responds to your April 26, 2007 letter requesting clarification on packaging used for shipment of "UN 3373, Biological Substance, Category B" and "UN 1845, Carbon dioxide, Aviation Organization (ICAO) Technical Instructions, as well as the Hazardous Materials solid" (dry ice) using Packing Instruction 650 and 904 under the International Civil must be manufactured by the same vendor, or, if packaging components may be comprised Regulations (HMR), 49 CFR Parts 171-180. Specifically, you ask if the packaging system of similar products manufactured by various vendors. According to your letter, your shipment consists of infectious substances (HIV or HBV blood/serum/plasma) on dry ice refrigerant assigned to "UN 3373, Biological Substance, Instructions 650 and 904 of the IATA Dangerous Goods Manual. The International Ai Category B" and "UN 1845, Carbon dioxide, solid" (dry ice), shipped under Packing Transport Association's Dangerous Goods Division advised you that there is no specific vendor under the IATA guidance book. You were further advised to contact the DOT for requirement that all components of a packaging system be manufactured by the same additional clarification under the HMR. You ask if packaging components comprised of similar various vendor products are acceptable packaging under the HMR. The answer is yes. "Infectious Substance, Category B" and "Carbon dioxide, solid" (dry ice) must be packaged in accordance with provisions in §173.199 of the HMR. Additionally, dry ice must also meet provisions in §173.217. There is no requirement under the HMR for the packaging system for "Infectious Substance, Category B" to be manufactured by the same vendor. Therefore, packaging for this shipment is acceptable if it meets all requirements in §§ 173.199 and 173.217 of the HMR. I hope this answers your inquiry. Office of Hazardous Materials Standards Chief, Standards Development 173.217 173.199 173.476 070088#

Page 2Drakeford, Carolyn <PHMSA> From: To: Sent: Thursday, April 26, 2007 11:46 AM INFOCNTR <PHMSA> Boothe Subject: FW: Information Center Comments/Questions Drakeford, Carolyn <PHMSA> 1133:214 Carolyn, 3 ASticability Could you enter this in the interps database for us? Thanks! 07-0088 Erin -----Original Message----- Sent: Thursday, April 26, 2007 11:32 AM From: nih-esprit-repository@niaid.nih.gov [mailto:nih-esprit-repository@niaid.nih.gov] To: INFOCNTR < PHMSA> Subject: Information Center Comments/Questions Below is the result of your teedback torm. esprit-repository@niaid.nih.gov) on Thursday, It pril bitted at 11: 2-277 Brown (nih- Email: nih-esprit-repository@niaid.nih.gov Name: Ms. Shawn Brown 173.476) Category: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 - Phone: (301) 846-7457 Comments: Dear Office of Hazmat, infectious substances (HIV or HBV blood/serum/plasma) on dry ice refrigerant that are I am seeking written guidance regarding packaging requirements for the shipment of shipped using Packing Instructions 650 and 904. assigned to UN 3373 (Biological Substance, Category B) and UN 1845 (Dry Ice), and will be packaging system (secondary leakproof receptacle, absorbent, Is it a requirement that the entire various vendor products? manufactured by the same vendor, or, Per a reply from the IATA DGs division, there is no specific can packaging components be comprised of similar requirement that all components of a packaging system be manufactured by the same vendor, contact you for guidance on this matter. but I was advised to consult with the US DOT on this matter. The US DOT advised me to For example, a proposed shipping system may consist of the following: - primary leakproof receptacles | cryogenic fibreboard grid boxes (1.8 mL leakproof cryovials) secured in 81-cell 2" - secondary leakproof packaging which is also capable of withstanding, internal pressure of 95 kPA in the temperature range of -40*C to 55*Cl (ex. manufactured by without leakage, an All-Pak, Exakt-Pak, - enough absorbent between the primary and secondary receptacles to absorb the entire or Inmark & certified by an outside company) contents in the event of leakage gas - polystyrene cooler (Saf-T-Pak product) which will permit the release of carbon dioxide - List of itemized contents between the secondary and outer packaging - STP-310 outer rigid box (Saf-T-Pak product) that is UN 2814 certified for PI 602 & consignee contact infornation - The outer box will be appropriately labeled with applicable markings, including shipper part of a complete packaging, acceptable per US DOT/HAZMAT regulations? Is the use of the individual vendor packaging components as listed above use guidancer as#

Page 3know. this matter is greatly appreciated. If you need additional information, please let me With kind regards, Ms. Shawn K. Brown Ms. Shawn K. Brown (Contractor) ************************************** 1050 Boyles Street SAIC-Frederick, Inc. / NCI-Frederick Frederick, MD 21702 USA +1 301 846 6025 Fax +1 301 846 7457 Phone#