Do Dangerous Goods regulations affect Human Organs for Transplant?

16 Dec, 2010 by  Michael Gotz

A question that sometimes arises when new Dangerous Goods regulations are introduced by IATA or any other regulatory body is how the shipments of human organs for transplant may be affected. Those of you who work with Organ Procurement Centers may feel relieved knowing that the Dangerous Goods regulations do not apply to them.

Human organs for transplant, and blood/tissue as well, have a unique place in the hearts of regulators: they are completely not regulated as hazardous. (See IATA DGR 3.6.2.2.3.5)

There are specific rules in both the IATA Air Dangerous Goods Regulations and, for our purposes here, the US DOT HAZMAT Regulations (49CFR) that exempt these commodities from hazmat regulation.

However, we have come across situations when some individuals at some airlines failed to recognize this. There is a quite easy way to prevent misunderstanding. It is not in the Regulations, but my suggestion is to add the following statement when completing the Air Waybill:

HUMAN ORGAN FOR TRANSPLANT
NOT RESTRICTED-NON HAZARDOUS

The word "transplant" is critical here because that is the reason the government provides leeway -- someone needs it for lifesaving purposes.

Taking it a step further, and again I don't see this in the Regulations, but I use the same exemption even if the organ is known to be infected with, say, HIV or Hep B, which would ordinarily be considered Dangerous Goods. The rules do not except this condition, so long as the organ really is going to be used for transplant soon.

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About Michael Gotz
HAZMAT Training & Compliance

Michael Gotz has developed IATA-certified Dangerous Goods training programs and has been a panelist in numerous IATA Dangerous Goods international conferences. He is the author of published journal articles on the subject of... Read more.

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