I received this email January 25th from a customer who had attended one of my Training Seminars in the past:
How have you been? You said to contact you if we have any questions. I was asked a question and I would like you to please review my answer. Can you help me out?
Can a 6.2 category B infectious substance be shipped in a personal or company vehicle?
Yes, a company vehicle can be used to transport a 6.2 category B substance, if the following exemptions are met.
49 CFR 173.134 (b)(10) allows an exception to using a certified hazmat transporter to transport a category B substance for a patient sample (not a culture) and the private or contract carrier would have
to be used exclusively to transport such materials. The vehicle couldn’t be a private vehicle but could be a company fleet vehicle. The vehicle could not be used for transporting anything else during that individual trip. The vehicle couldn’t be a general delivery vehicle making several stops. DOT training would be required and a Shipping document and DOT packaging would be needed.
49 CFR 173.6 Materials of Trade allows an exemption for small quantities of biological product, human or animal samples for research, diagnosis, disease treatment or prevention etc. The packaging would have to be securely closed and protect against damage and leaking. The driver would have to know what they are shipping and if a reportable quantity is present and the material of trade regulations. Does not require training or a shipping document.
My reply later that day:
Your answer may be correct. Give me a day or two to review and reply.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
International and Domestic
Daniels Training Services
My full response on January 26, 2016:
Thanks for contacting me. I’ll do my best to answer your questions below.
- You are correct about the exception at 49 CFR 173.134(b)(10). Transportation must be for the purpose of, “…being transported for research, diagnosis, investigational activities, or disease treatment or prevention…”. However, 173.134(b) states that excepted materials are not subject to the HMR as Division 6.2. If there is nothing else to make them subject to the HMR (e.g. they are also a Class 3 Flammable Liquid), then it is not subject to the HMR at all and neither HazMat Employee training nor a shipping paper is required. Read my article: Exceptions to Division 6.2 Infectious Substances.
- You are also correct about the use of the Materials of Trade Exception.
Please don’t hesitate to contact me with any other questions.
Interested in a Webinar that covers this topic, and more!
I think I answered his question satisfactorily:
Thanks Dan for your response. I look forward to attending future training sessions with you.
This customer did his own research before contacting me but you don’t have to! If you have a question about the transportation of hazardous materials or the management of waste – hazardous, universal, used oil, even non-hazardous – don’t hesitate to contact me.
Note that even with the use of the exception at 49 CFR 173.134(b)(10), HazMat Employee training is still required. I can provide you with that training!