Neoteryx — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 January 6, 2021 Stuart Kushon Neoteryx 421 Amapola Avenue Torrance, CA 90501 Reference No. 20-0077 Dear Mr. Kushon: This letter is in response to your September 16, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to infectious substances. Specifically, you ask for assistance classifying a dried blood sample under the following circumstances: • A dried blood sample on absorbent material when the blood sample on the material comes from a community study on influenza infection where the subjects are not known or presumed to be infected. • A dried blood sample on absorbent material when the blood sample on the material comes from a community study on COVID-19 infection where the subjects are not known or presumed to be infected. • A dried blood sample on absorbent material when the blood sample on the material comes from a subject that is presumed to be infected with influenza. • A dried blood sample on absorbent material when the blood sample on the material comes from a subject that is presumed to be infected with COVID-19. In each circumstance, § 173.134(b)(9) states that dried blood spots placed on absorbent filter paper or other material are not subject to the requirements of the HMR. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3Ballengee 20-0077 From: INFOCNTR (PHMSA) To: Date: Dodd, Alice (PHMSA); Hazmat Interps Subject: FW: Request for interpretation Thursday, September 17, 2020 12:45:39 PM Attachments: image002.png Hello Alice, Please see below for a letter of interpretation request. Please contact our office with any questions. Thank you, Sarah (HMIC) From: Stuart Kushon [mailto:stuartk@neoteryx.com] Sent: Wednesday, September 16, 2020 3:03 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Request for interpretation CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Hello, I have spoken with your team at 1 800-467-4922. I called from my cell phone at 505-231-0887. Here is my information. Name: Stuart Kushon Company: Neoteryx Physical Address: 421 Amapola Avenue, Torrance, CA 90501. My questions are regarding material classification of a dried blood sample on absorbent material (49 CFR 173.134). 1. What is the substance classification of a dried blood sample on absorbent material when the blood sample on the material comes from a community study on influenza infection where the subjects are not known or presumed to be infected? 2. What is the substance classification of a dried blood sample on absorbent material when the blood sample on the material comes from a community study on COVID-19 infection where the subjects are not known or presumed to be infected? 3. What is the substance classification of a dried blood sample on absorbent material when the blood sample on the material comes from subject that is presumed to be infected with influenza?#

Page 44. What is the substance classification of a dried blood sample on absorbent material when the blood sample on the material comes from subject that is presumed to be infected with COVID-19? Many Thanks, Stuart Stuart A. Kushon, Ph. D. Chief Scientific Officer “What I can not create, I do not understand” – R. Feynman Neoteryx 421 Amapola Avenue Torrance, CA 90501 Tel: 310.405.6384 Email: StuartK@Neoteryx.com Website: www.neoteryx.com The information contained in these documents is confidential, privileged and only for the information of the intended recipient and may not be used, published or redistributed without the prior written consent of Neoteryx, LLC.#