DOT Says “NO” to Dirty Money

In a recent interpretation letter to the US DOT, the Federal Reserve Bank of San Francisco asked about the applicability of the Hazardous Materials Regulations regarding the transportation of “contaminated currency.” Contaminated currency is typically currency that is exposed to human blood, mildew, and dye pack (pepper spray) elements. The DOT responded that currency collected from banks that has been contaminated by a variety of substances (e.g. blood, body fluids, sewage, dye pack chemicals, etc.) is not regulated as a hazardous material (e.g. infectious substance). In order to meet the infectious substance requirement, the currency would have to contain a pathogen that has the potential to cause disease in humans or animals and based on the information supplied by the Bank, soiled currency does not meet the infectious substance definition. DOT then went on to explain that if a government entity such as the Federal Reserve Bank, prepared packages of “contaminated currency” that qualified as infectious substances but were transported by the Federal Reserve Bank, using Federal Reserve drivers, the shipment would not be subject to the HMR. The HMR would only apply if the Federal Reserve Bank offered this shipment to a commercial carrier for transport. This is the best reason I’ve heard for using a credit card!