1 · Most of it is not a hazardous material at all
49 CFR 173.134(b) lists what is not subject to the Hazardous Materials Regulations as a
Division 6.2 material. Paragraph (b)(7) is the load-bearing citation for this entire service:
Blood collected for the purpose of blood transfusion or the preparation of blood
products; blood products; plasma; plasma derivatives; blood components; tissues or organs intended for use
in transplant operations; and human cell, tissues, and cellular and tissue-based products regulated under
authority of the Public Health Service Act and/or the Food, Drug, and Cosmetic Act.
49 CFR §173.134(b)(7)
No shipping papers, no hazard labels, no shipper's declaration, no notification to pilot-in-command
— for the material itself. Related exceptions cover donor screening samples drawn at collection
(b)(8), dried blood spots (b)(9), non-infectious cells
and tissue cultures (b)(2), and licensed biological products including vaccines
(b)(6).
Routine clinical testing is excepted too, under (b)(11) — specimens for
testing not related to the diagnosis of an infectious disease, where there is a low probability the
sample is infectious. That covers drug and alcohol screens, cholesterol, glucose, PSA, kidney and liver
panels, pregnancy testing, and cancer biopsies.
2 · What we do not accept: infectious substances
Specimens shipped for the diagnosis of an infectious disease fall outside the exceptions above.
Depending on the organism they are classified either as Category A (UN2814 or UN2900) or as
Biological Substance, Category B — UN3373, governed by 49 CFR 173.199
and IATA Packing Instruction 650.
AeroAcumen does not currently accept either classification. If your shipment is declared as
UN2814, UN2900 or UN3373, we are not your carrier for it and will say so at the quote stage rather than at
the ramp.
In practice this excludes less than shippers often expect. Routine clinical testing not related to
infectious-disease diagnosis is exempt under §173.134(b)(11), and donor
screening samples drawn as part of collection are exempt under §173.134(b)(8)
— so the great majority of laboratory and donor-screening work moves as ordinary cargo. Where the
classification is genuinely unclear, we ask for your shipper's determination in writing before acceptance.
3 · The refrigerant is the regulated part — and that's our advantage
An exempt specimen does not stay exempt if something else in the box is regulated:
If an item listed in paragraph (b) or (c) of this section meets the definition of
another hazard class or if it is a hazardous substance, hazardous waste, or marine pollutant, it must be
offered for transportation and transported in accordance with applicable requirements of this subchapter.
49 CFR §173.134(d)
In practice that means one thing: dry ice. Solid carbon dioxide is UN1845, Class 9, and it
converts an otherwise unregulated medical shipment into a dangerous-goods shipment requiring a will-carry
operator. Every frozen product in this category — frozen plasma and cryoprecipitate, frozen
musculoskeletal and skin allograft, frozen nerve graft — travels this way. It is exactly the cargo
we are certificated to accept.
Note also that the broad patient-specimen exception at §173.134(b)(10)
applies only to materials carried by motor vehicle in a vehicle used exclusively for them. It is a
ground-only relief — which is precisely why hazmat authority matters more in the air than on the
road.
4 · Who regulates whom
Shippers frequently assume a carrier needs its own FDA registration, CLIA certificate, or OPTN standing
to touch this cargo. None of that is so, and the rules say it plainly.
