The Jackson Laboratory-West — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration OCT 9 2009 1200 New Jersey Ave. S.E. Washington. D.C. 20590 Ms. Kristela Rarnos The Jackson Laboratory-West 49 10 Raley Boulevard Sacramento, CA 95838 Ref. No. 09-0 189 Dear Ms. Rarnos: This responds to your August 18,2009 request for clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80) applicable to the transportation of live animals implanted with non-infectious tumor fragments or blood cells (stem cells). You indicate that the animals are used for research and ask whether they are subject to the HMR. The answer is no. In accordance with § 1 73.134(b)(l), a material that does not contain an infectious substance or that is unlikely to cause disease in humans or animals is not subject to the requirements of the HMR applicable to the transportation of Division 6.2 materials. I hope this answers your inquiry. If you need further assistance, do not hesitate to contact this Office. Sincerely, harles E. Betts hief, Standards Development e of Hazardous Materials Standards#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) Wednesday, August 19,2009 8:31 AM Drakeford, Carolyn (PHMSA) FW: Hazmat Information Center Feedback: Other Questions? 3 17 3 . /3g ----- Original Message----- From: PHMSA-Feedback [mailto:PHMSA-Feedback] Sent: Tuesday, August 18, 2009 4:24 PM To: PHMSA HM Infocenter; PHMSA Webmaster Subject: Hazmat Information Center Feedback: Other Questions? REQUEST FOR WRITTEN LETTER OF INTERPRETATION. 49 CFR 173.134 Does shipping animals that has tumor fragments or core blood cells (stem cells) implanted/injected in them fall under 49 CFR 173.134 exception 11? Please provide a written letter of interpretation. Thank you. Sincere1 y, Kristela Ramos ----------- Name: Kristela Ramos Email: kristela.ramos@jax.org Phone: 916-469-2580#

Page 3Page 4 of 5 Sent: Friday, September 11, 2009 7:38 AM To: Kristela Ramos Cc: deborah.boothe@dot.gov Subject: FW: Request for Mailing Address for Letter of Clarification, Ref. No. 09-0189 Importance: High Good morning Ms. Ramos, I hope you're having a great day! I'm continuing to work on your letter of clarification. However, I need some additional information in order to complete the letter. In your fax you ask: Does shipping animals that has tumor fragments or core blood cells (stem cells) implantedlinjected in them fall under 49 CFR 173.1 34(b)(l1) exceptions? Are these animals alive or dead? ALIVE Do these tumor fragments or core blood cells (stem cells) contain an infectious agent? NO Do you suspect it's a Category A? NO Are these animals going to be used for research, diagnosis, etc. or routine testing? RESEARCH FYI: If these are live animals with an infectious agent, §173.196(c) requires an approval form the Associate Administrator for Hazardous Materials Safety (CA). Thank you Ms. Ramos for the additional information. Deborah Boothe Transportation Regulations Specialist DOTIPHMSA Office of Hazardous Materials StandardslPHH-I 0 From: Boothe, Deborah (PHMSA) Sent: Thursday, August 27, 2009 1:00 PM To: 'Kristela Ramos' Subject: RE: Request for Mailing Address for Letter of Clarification, Ref. No. 09-0189 Thanks so much Ms. Ramos! From: Kristela Ramos [rnailto:Kristela.Ramos@jax.org] Sent: Thursday, August 27,2009 12:18 PM To: Boothe, Deborah (PHMSA) Subject: RE: Request for Mailing Address for Letter of Clarification, Ref. No. 09-0189 Ms. Boothe, Please see below for my mailing address: Kristela Ramos The Jackson Laboratory -West 4910 Raley Boulevard Sacramento, CA 95838 Please let me know if there is anything else you need. Thank you.#