Classification of Hepatitis Antigen
Pipeline and Hazardous Materials Safety Administration · Mar 5, 1997 · Reference No. 97-0171
Interprets: 49 CFR § 172.402, 49 CFR § 173.2a, 49 CFR § 173.425, 49 CFR § 173.427
Reggie’s quick take
A company that ships a radioactive and infectious material asked how to classify and describe a hepatitis antigen shipment. The material is LSA, in 12 ml bottles packed 100 to a box, and moves about one mile on public highway in company vehicles. PHMSA said the hazard class is Class 7 (radioactive), because the package exceeds limited-quantity activity limits (§ 173.2a(a)). The shipping paper description is "Radioactive material, LSA, n.o.s. (Hepatitis Antigen), 7, UN 2912." If the shipment meets exclusive use rules, the package does not need a "RADIOACTIVE" label, but it must be marked "Radioactive - LSA" and labeled "INFECTIOUS SUBSTANCE" (§ 172.402(d)).
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in reply to your letter and telephone conversation with a member of my staff concerning the hazard class of a material, Hepatitis antigen, that meets the definition of both Division 6.2 (infectious) and Class 7 (radioactive). I apologize for the delay in responding to your inquiry and any inconvenience this may have caused.
You identify the subject material as ten milliliters of low specific activity (LSA) material placed in a 12 ml, high-density polyethylene bottle, with 100 bottles packed in one fiberboard box in accordance with former 49 CFR 173.425(b). Effective April 1, 1996, the requirements in this section were redesignated to § 173.427 (Docket HM-169A, 9/28/96). The material is transported approximately one mile on a public highway by company employees in company owned vehicles from the manufacturing site to the distribution center for repackaging.
Q1. How do I classify and describe the above-described material?
A1. As prescribed in § 173.2a(a), because the contents of the package exceed the activity limits for a limited quantity of Class 7 material, the hazard class is Class 7.
The material may be described on shipping papers with the following basic description:
"Radioactive material, LSA, n.o.s. (Hepatitis Antigen), 7, UN 2912."
Q2. How do I mark, label, and package this material?
A2. Provided the shipment conforms to "exclusive use" provisions, this material may be packaged in a strong, tight package that prevents leakage of the radioactive content under normal conditions of transportation in accordance with § 173.427(b)(3).
The exterior of each non-bulk package must be stenciled or otherwise marked "Radioactive - LSA" in accordance with § 173.427(a).
Under provisions for "exclusive use" shipment controls in § 173.427(a), there is no requirement to label the package "RADIOACTIVE." However, the package must be labeled "INFECTIOUS SUBSTANCE" to communicate the material's subsidiary hazard. See § 172.402(d).
I hope this information is helpful. Should you have further questions, please contact us.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.