private carriers would currently 
result in cost increases of at least 
10 to 15 times the cost of transport 
through the U.S. mails. Where 
this increased cost would have to 
be absorbed in research or medical 
diagnostic services is not known, 
although it will likely be by users 
of services. The implementation of 
the proposed regulation by the 
U.S. Postal Service may result in 
carriers other than the U.S. Postal 
Service not accepting etiologic 
agents and/or substantial in- 
creases in the cost over present 
rates for transport by alternative 
carriers. , 
— * These increase nosts and diffi- 
culties may result in unmarked 
and perhaps even improperly 
packaged shipments through the 
U.S. mail. Thus, if the proposed 
ban is instituted, it could result in 
less safety in shipment of etiologic 
agents than is experienced under 
the current regulations. 
ASM considers the proposed 
ban by the Postal Service on the 
shipping of etiologic agents 
through the mail an action of un- 
! warranted concern, particularly 
since to date there has not been a 
single documented infection re- 
sulting from the proper practice of 
mailing such specimens. It is fur- 
ther recognized by ASM and other 
organizations that the U.S. Postal 
Service, through providing the 
mechanisms for the shipment of 
etiologic agents and diagnostic 
specimens, has significantly con- 
tributed to the public health and 
well-being of the nation. 
Clearly, continuation of this 
function by the U.S. Postal Service 
is essential to the national health 
and economy. The use of current 
packaging and labeling proce- 
dures and standards has proven to 
be safe and cost-effective. We 
nonetheless strongly support the 
need for periodic reassessment of 
the effectiveness of estahnsned 
procedures, which should be done 
with careful consideration of the 
entire body of experience and in- 
formation developed over previous 
years. 
Along with 12 other organiza- 
tions, the ASM has submitted the 
following recommendations to the 
U.S. Postal Service: 
• That since the PHS (CDC) and 
the Department of Transporta- 
tion (DOT), both involved with 
various aspects of regulation in 
the shipment of etiologic agents 
and diagnostic specimens, are 
considering revisions to current 
regulations, the U.S. Postal Ser- 
vice should participate with the 
PHS (CDC) and DOT in forming 
a federal interagency committee 
to review the appropriateness of 
current regulations for packag- 
ing and shipping etiologic agents 
and diagnostic specimens so that 
guidelines and regulations may 
be established. It is also recom- 
mended that this committee 
seek the participation of nongov- 
ernmental organizations to as- 
sist in providing expertise and 
comment prior to the publication 
of proposed regulations. It is fur- 
ther encouraged that the inter- 
agency committee remain in ex- 
istence to periodically review 
regulations, thus ensuring safe 
and cost-effective transport of 
etiologic agents and diagnostic 
specimens. 
• That there be initiated a review 
of definitions describing etiologic 
agents and diagnostic specimens 
to identify more precisely poten- 
tial risk(s) and define packaging 
requirements. Current terms 
and definitions have caused 
some confusion. It is unclear, for 
example, what should be consid- 
ered a diagnostic specimen, and 
in turn, when that specimen 
should be labeled an etiologic 
agent. The term etiologic agent 
is broad and does not segregate 
hosts and levels of potential risk. 
More appropriate terms and ac- 
curate definitions should greatly 
improve the current system. 
• That there be established an ed- 
ucation and training program 
for shippers, hsncilers, and recip- 
ients of etiologic agents and di- 
agnostic specimens that empha- 
sizes compliance with 
regulations, proper packaging, 
and shipping. The program 
should involve governmental 
and nongovernmental organiza- 
tions in order to educate the 
broadest possible range of indi- 
viduals. The College of Ameri- 
can Pathologists, the National 
Committee for Clinical Labora- 
tory Standards, the American 
Society of Clinical Pathologists, 
and the Association of State and 
Territorial Public Health Labo- 
ratory Directors are important 
organizations that should be 
called on to assist in the develop- 
ment of such a program. 
• That there be enforcement with 
penalties for those who violate 
regulations on the shipping and 
packaging of etiologic agents 
and diagnostic specimens. Pen- 
alty actions must be made 
widely known. Procedures for 
prosecution of violators should 
be clearly established by the pro- 
posed Federal Interagency Com- 
mittee. These procedures should 
be made known not only to 
postal employees but also to all 
those who ship agents and spec- 
imens through the mail. 
Independently, ASM has also 
recommended that etiologic 
agents currently requiring a PHS 
permit for transport be sent by 
registered mail. Shipment by reg- 
istered mail involves minimal in- 
creases in cost while providing a 
means of tracking each shipment 
from the shipper to the recipient. 
In addition, out of our concern for 
the safe and effective transport of 
etiologic agents, we offer our re- 
sources and the expertise of our 
membership to further assist in 
the improvement of methods for 
shipment of etiologic agents. 
It is important that there not 
be overreaction to any perceived 
problems with the current regula- 
tions gover ning the transport of 
etiologic agents. Current regula- 
tions for the shipping of etiologic 
agents and diagnostic specimens 
through the U.S. mail have been 
— — 1- Ta -T* ** ^ »*.'*_ r ^ r 
OUv^COOi. cLL CkXAVA dale p i y 
followed. The recommendations 
dted here, along with others, can 
lead to an even better, safer sys- 
tem of cost-effective transport of 
cultures and biological materials. 
ASM News 
[406] 
Recombinant DNA Research, Volume 13 
