# Henry Ford Hospital — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 08-0247
- **title:** Henry Ford Hospital — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2008-10-30
- **effective on:** Not available
- **summary:** 08-0247 response to Henry Ford Hospital concerning 171.1, 173.197.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-08-0247.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-08-0247.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-08-0247
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080247.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous Materials
Safety Administration
1200 New Jersey Ave., SE
Washington, DC 20590
Ms. Carolie Horvath
Henry Ford Hospital
2799 W. Grand Blvd.
Detroit, MI 48202
Ref. No. 08-0247
Dear Ms. Bassine:
This is in response to your September 29,2008 email regarding the applicability of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 100-1 80) to the transportation of chemotherapy
medications.
In your email, you state that you have reviewed the Material Safety Data Sheet (MSDS) for a few
select chemotherapy medications and the shipping information for these agents indicates that the
materials are "not DOT regulated." You request whether these chemotherapy medications
transported by same-day local courier service are regulated under the HMR. You also request
guidance on proper packaging and hazardous communication to transport these materials in
accordance with the HMR.
It is the opinion of this Office that the materials described in your letter do not meet the definition of
a hazardous material and, therefore, are not required to be transported in accordancewith the HMR.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Susan Gorsky 0
Acting Chief, Standards Development
Office of Hazardous Materials Standards

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Drakeford. Carolvn <PHMSA>
From:
Sent:
To:
Subject:
INFOCNTR <PHMSA>
Monday, September 29,2008 10:18 AM
Drakeford, Carolyn <PHMSA>
FW: Information Center Comments/Questions
Carolyn,
Another request for interpretation.
Thanks,
Rob
----- Original Message-----
From: Chorvatl@hfhs.org [mailto:Chorvatl@hfhs.org]
Sent: Friday, September 26, 2008 2:00 PM
To: INFOCNTR <PHMSA>
Subject: Information Center Cornments/Questions
Below is the result of your feedback form. It was submitted by Carolie Horvath (Chorvatl
@hfhs.org) on Friday, September 26, 2008 at 13:59:47.
Name: Carol ie Horvat h
Category: Shippers-General Requirements for Shipments and Packagings (Sections 173.1 -
173.476)
Organization: Henry Ford Hospital
City: Detroit
State: Michigan
Zip Code: 48292
Phone: 313-916-8749
Comments: I had contacted Hazmat via telephone on two separate occasions, and have gotten
information that is unclear to me, and I am hoping for a written response. Our hospital
will be sending chemotherapy drugs, via same day local courier service, to our satellite
sites (within a 30 mile distance). I have examined 49 CFR Part 172/173, and am unsure if
chemotherapy medications fall under Class 6.1 Toxic substances. I have reviewed a few MSDS
sheets for a few select chemotherapy medications, and the shipping information for these
agents states "not DOT regulated", keeping in mind that these substances can be irritating
on contact. So, I remain unclear as to which regulations need to be followed, if any, for
sending these medications via courier. Are they exempt (meaning they do not classify as
6.1 Toxic)? I had assumed, perhaps wronlgy so, that all chemotherapy medications were
Class 6.1. We want to ensure our compliance with any applicable regulations for shipping
and pack!
aging these medications. Can you please provide some direction on how to properly pack.ig{;
and label these medications ? Some of the medications will be sent in vials, and others
will be reconstituted in an IV bag.
Thank you in advance for any assistance that you can provide.
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