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<blockquote data-quote="Floridacargocat" data-source="post: 489902" data-attributes="member: 6168"><p>Would like to submit an interesting interpretation from the DOT regarding blood and HazMat</p><p>Source: <a href="http://phmsa.dot.gov/portal/site/PHMSA/menuitem.ebdc7a8a7e39f2e55cf2031050248a0c/?vgnextoid=934d5794ed745110VgnVCM1000009ed07898RCRD" target="_blank">http://phmsa.dot.gov/portal/site/PHMSA/menuitem.ebdc7a8a7e39f2e55cf2031050248a0c/?vgnextoid=934d5794ed745110VgnVCM1000009ed07898RCRD</a></p><p> </p><p>"</p><p><strong>PHMSA Interpretation #03-0113</strong></p><p></p><p><strong>Aug 30, 2004</strong></p><p><strong>PHMSA Response Letter </strong></p><p></p><p>Aug 30, 2004</p><p> </p><p>Ellis Jacobs, Ph.D., DABCC Reference No. 03-0113 </p><p>Director, Clinical Laboratory </p><p>Evaluation Program </p><p>Wadsworth Center </p><p>New York State Department of Health </p><p>P.O. Box 509 </p><p>Albany, NY 12201-0509 </p><p>Dear Dr. Jacobs: </p><p>This is in response to your letter asking if whole blood samples offered for transportation by your program to administer various proficiency tests for the purpose of licensing laboratories in the State of New York are subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). From telephone conversations with Ms. Kathi Wagner of your staff, we understand the whole blood has been tested and determined to not meet the definition of a hazardous material, but before being offered for commercial transportation to the laboratories for analysis, various chemicals, parasites, or microbiological agents may be added. We apologize for the delay in responding and any inconvenience this may have caused.</p><p>You are correct that blood collected for transfusion and biological products subject to approval by the Food and Drug Administration or the U.S. Department of Agriculture are not subject to the HMR (see § 173.134(b)). However, the samples you use for your various test programs may be subject to the HMR if you add chemicals or other materials to the samples.</p><p><span style="color: red">Blood and other biological samples that do not meet the definition of a Division 6.2 (infectious) material in § 173.134(a) or the definition of another class of hazardous material in Part 173 are not subject to the HMR.</span> Thus, the blood samples you transport for your engraftment monitoring, immunohematology proficiency test, and parentage/identity testing programs are not regulated under the HMR. Similarly, if the serum samples you transport for your clinical chemistry, cytokines, diagnostic immunology, endocrinology, hematology, oncology, parasitology, therapeutic substance monitoring, and clinical and toxicology proficiency test programs are not infectious and do not meet the definition of another hazard class, they are not subject to the HMR.</p><p>Sincerely, </p><p> </p><p>Hattie L. Mitchell, Chief </p><p>Regulatory Review and Reinvention </p><p>Office of Hazardous Materials Standards"</p><p> </p><p>So, until the blood sample has been confirmed not be contagious or infectious, it is classified as "non-hazardous"</p><p>You can look up all the interpretation from DOT under </p><p><a href="http://phmsa.dot.gov/hazmat/regs/interps" target="_blank">http://phmsa.dot.gov/hazmat/regs/interps</a></p><p>and type in "blood" or "blood samples".</p><p>I understand the concern of the person involved that all the necessary precautions should be taken, but common sense should not be excluded.</p><p>In the extreme, your colleague on the left or right is cutting his finger and needs a bandaid (and you do not know nor ask about his possible infectious state), what would be the proper procedure in providing him/her a simple band-aid?</p><p>Re "survival of viruses in blood outside a host", suggest you go to Google or wikipedia and obtain the information you are looking for. Hope this helps.</p></blockquote><p></p>
[QUOTE="Floridacargocat, post: 489902, member: 6168"] Would like to submit an interesting interpretation from the DOT regarding blood and HazMat Source: [URL]http://phmsa.dot.gov/portal/site/PHMSA/menuitem.ebdc7a8a7e39f2e55cf2031050248a0c/?vgnextoid=934d5794ed745110VgnVCM1000009ed07898RCRD[/URL] " [B]PHMSA Interpretation #03-0113[/B] [B]Aug 30, 2004[/B] [B]PHMSA Response Letter [/B] Aug 30, 2004 Ellis Jacobs, Ph.D., DABCC Reference No. 03-0113 Director, Clinical Laboratory Evaluation Program Wadsworth Center New York State Department of Health P.O. Box 509 Albany, NY 12201-0509 Dear Dr. Jacobs: This is in response to your letter asking if whole blood samples offered for transportation by your program to administer various proficiency tests for the purpose of licensing laboratories in the State of New York are subject to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). From telephone conversations with Ms. Kathi Wagner of your staff, we understand the whole blood has been tested and determined to not meet the definition of a hazardous material, but before being offered for commercial transportation to the laboratories for analysis, various chemicals, parasites, or microbiological agents may be added. We apologize for the delay in responding and any inconvenience this may have caused. You are correct that blood collected for transfusion and biological products subject to approval by the Food and Drug Administration or the U.S. Department of Agriculture are not subject to the HMR (see § 173.134(b)). However, the samples you use for your various test programs may be subject to the HMR if you add chemicals or other materials to the samples. [COLOR=red]Blood and other biological samples that do not meet the definition of a Division 6.2 (infectious) material in § 173.134(a) or the definition of another class of hazardous material in Part 173 are not subject to the HMR.[/COLOR] Thus, the blood samples you transport for your engraftment monitoring, immunohematology proficiency test, and parentage/identity testing programs are not regulated under the HMR. Similarly, if the serum samples you transport for your clinical chemistry, cytokines, diagnostic immunology, endocrinology, hematology, oncology, parasitology, therapeutic substance monitoring, and clinical and toxicology proficiency test programs are not infectious and do not meet the definition of another hazard class, they are not subject to the HMR. Sincerely, Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards" So, until the blood sample has been confirmed not be contagious or infectious, it is classified as "non-hazardous" You can look up all the interpretation from DOT under [URL]http://phmsa.dot.gov/hazmat/regs/interps[/URL] and type in "blood" or "blood samples". I understand the concern of the person involved that all the necessary precautions should be taken, but common sense should not be excluded. In the extreme, your colleague on the left or right is cutting his finger and needs a bandaid (and you do not know nor ask about his possible infectious state), what would be the proper procedure in providing him/her a simple band-aid? Re "survival of viruses in blood outside a host", suggest you go to Google or wikipedia and obtain the information you are looking for. Hope this helps. [/QUOTE]
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