Shipping and Receiving Hazardous Materials
This document is designed as a tool to assist campus personnel in understanding the federal regulatory requirements that apply to shipping and receiving hazardous materials. There are Department of Transportation (DOT) training requirements for those who receive hazardous materials or offer materials to others for shipment. Additional training is required by the DOT and the International Air Transport Association (IATA) for personnel that perform any of the following tasks:
- Prepare paperwork for hazardous material shipments
- Package hazardous materials for shipment
- Label or mark packages containing hazardous materials
- Load or transport hazardous materials, regardless of the amount of material
The training requirements are discussed in Section V.
Reading this document and completing the online “Awareness Training for the Transport of Hazardous Materials” offered by DRS does not meet the requirements set forth in the regulations discussed below. In order to ship hazardous materials legally, you must obtain additional training and certification from a commercial vendor specializing in DOT and IATA compliance.
The DOT has established regulations for domestic transport (within the United States) of hazardous materials by rail, air, vessel (ships), and motor carrier (ground). IATA has established guidelines exclusively for the transport of dangerous goods by air (both domestic and international). The DOT term “Hazardous Material” and IATA term “Dangerous Good” are used interchangeably in this document.
As a result, when shipping via air (international or domestic), you must use the IATA guidelines. Each carrier may have special provisions that must be met before a package containing dangerous goods can be transported on an aircraft. In addition, when shipping internationally, some countries have specific requirements for dangerous goods. All of these are addressed in the IATA Dangerous Goods Regulations.
Links to information found in this guidance document:
- Section II Definition of a Hazardous Material
- Section III How Do I know if a material is a Hazardous Material or Dangerous Good?
- Section IV DRS and Campus Personnel Responsibilities
- Section V Training
- Section VI Transporting Chemicals in Personal Vehicles and University Vehicles
- Section VII Reusing Boxes that were Marked for Hazardous Materials
II. Definition of a Hazardous Material
A hazardous material is defined as a substance or material that has been determined by the Department of Transportation to be capable of posing an unreasonable risk to health, safety and property when in transportation. Materials that are hazardous to the environment (i.e., hazardous substance, hazardous wastes, and marine pollutants) are also regulated.
Hazardous materials include but are not limited to:
- Laboratory chemicals
- Biological agents
- Radioactive materials
- Compressed gases
- Patient specimens
- Dry ice
- Refrigerants and related equipment
- Instruments/equipment that contain hazardous materials
Refer to Section III to determine if a material is classified as a hazardous material.
III. How do I know if a material is a Hazardous Material or a Dangerous Good?
It is the responsibility of the person who initiates the shipment of a material to determine (or seek assistance to determine) if the material meets the definition of a material. To determine if a material is regulated by the DOT, the following references in Title 49 of the Code of Federal Regulations (49 CFR) must be checked to see if the material is listed and/or if the material fits the definition of the hazard classes:
- § 172.101 – The Hazardous Materials Table
- § 172.101 Appendix A - Hazardous Substances Other Than Radionuclides
- § 172.101 Appendix B - List of Marine Pollutants
- § 173, Subparts C, D, & I – the nine DOT hazard classes
The Code of Federal Regulations can be viewed on line at: http://www.gpoaccess.gov/ecfr/. Search first by Title 49 –Transportation, then go to the sections listed above, identified by the § symbol.
The table below identifies the nine DOT hazard classes. Click on the link in the left column to view the DOT definition, and examples of materials that fit those classes.
|Class or Division No.||Name of Class or Division (for DOT definition and more examples, click on link at left)||49 CFR Reference|
|1.1 to 1.6||Explosives||§173.50|
|2.1 to 2.3||Compressed gases (including liquefied gases)||§173.115|
|3||Flammable (and combustible) liquids (i.e., alcohols, solvents, lubricants, paints)||§173.120|
|4.1 to 4.3||Solids that are flammable, spontaneously combustible, or dangerous when wet (i.e. Lithium alkyds, naphthalene, phosphorus, calcium hydride, sodium).||§173.124|
|5.1 and 5.2||Oxidizers and organic peroxides (i.e., bromates, chlorates, permanganates., hydrogen peroxide (>8%), benzoyl peroxide)||§173.127 and §173.128|
|6.1||Poisonous/Toxic (i.e., some pesticides, barium compounds, phenol, chloroform, and some biotoxins)||§173.132|
|6.2||Infectious substances (i.e. cultures and stocks, patient specimens, biological products, regulated medical waste, and toxins derived from animal, plant, or bacteria that contains or might contain an infectious substance)||§173.134|
|8||Corrosives (acids or bases which are corrosive to the skin and other materials having a pH of £ 5.5 or ³ 11.0)||§173.136|
|9||Miscellaneous hazardous materials (i.e., asbestos, dry ice, PCBs)||§173.140|
To determine if a material is regulated by IATA, refer to the IATA Dangerous Goods Regulations. This book is available for purchase from IATA directly, (http://www.iata.org/ps/publications/9065.htm), but is not available online to review.
Division of Research Safety (DRS)
- Inform campus personnel about regulatory requirements for shipping hazardous materials.
- Provide online “Awareness Training for the Transport of Hazardous Materials” training for campus personnel who receive hazardous materials or provide hazardous materials to another person to prepare for shipment.
- Provide campus personnel with information about commercial trainers that offer required training to those who prepare paperwork for hazardous material shipments; package hazardous materials for shipment; mark or label packages containing hazardous materials; or load or transport hazardous materials.
- Provide CD-ROM based shipping training for Class 6.2: Infectious Substances to campus personnel who package, label, or complete paperwork (e.g. air waybills, shipper’s declarations, manifests) for domestic or international transport. Please contact the Division of Research Safety Biological Safety Section via e-mail for more information.
- Provide campus personnel with information about commercial carriers that can ship hazardous materials.
Campus Units and Supervisors
- Provide or make arrangements for personnel to receive appropriate training (see Section V. Training).
- Comply with DOT and/or IATA regulations.
Campus Personnel Who Ship Hazardous Materials
- Determine if the material being shipped qualifies as a hazardous material or dangerous good (NOTE: Size of container, no matter how small, does NOT exclude it from regulations).
- Comply with DOT and/or IATA regulations.
- Acquire appropriate training (see Section V. Training).
- Acquire appropriate shipping materials (boxes, labels, etc.)
- Coordinate with a carrier (UPS, FedEx, etc.) to become a recognized hazardous materials shipper.
Campus Personnel Who Receive Hazardous Materials
- Acquire appropriate training (see Section V. Training)
Before any employee performs a function that is subject to DOT hazardous materials regulations or IATA dangerous goods regulations, that person must have initial training in the performance of that function. Refresher training is required every two years.
There are two groups of personnel who need training:
- Personnel who receive hazardous material shipments (storerooms, department, receiving, etc.) and those who provide materials to another person to prepare for shipment.
- These individuals are required to take Awareness Training for the Transport of Hazardous Materials, which provides a general understanding of hazardous material transport regulations and how to apply them. It also covers emergency response information and security awareness.
- This training is offered by DRS at: http://www.drs.illinois.edu/training/
- Personnel who prepare paperwork for hazardous material shipments; package hazardous materials for shipment; mark or label packages containing hazardous materials; or load or transport hazardous materials.
- These individuals are required to take Awareness Training for Shipping and Receiving Hazardous Materials (described above) offered by DRS at: http://www.drs.illinois.edu/training/
- In addition, they are required to have in-depth shipping training that provides an understanding of how to select proper packaging, complete paperwork correctly, etc.
- DRS can provide information on commercial vendors that provide specific training for packaging and shipping hazardous materials.
- When shipping infectious substances, contact DRS-Biological Safety Section (DRS-BSS) at 333-2755 for more information. The transport of infectious substances, patient specimens, and biological materials requires additional specialized training beyond that required for shipping chemicals. DRS can provide information about commercial vendors that offer appropriate training.
Note: Both groups of personnel will need additional training related to their specific work functions, such as hazard communication training, ergonomic training, fork-lift training, etc.
VI. Transporting Chemicals in Personal Vehicles and University Vehicles
Transporting chemicals in personal vehicles either on campus or to off-site research locations for University business is not a recommended practice. DOT regulations do not apply to personal transportation of hazardous materials. However, insurance companies may not cover claims involving the transportation of hazardous materials.
When transporting materials in University vehicles, the following precautions should be followed:
- Secondary containment should be used to contain any spill of the hazardous materials being transported.
- Incompatible chemicals should be separated into different secondary containers.
- Hazardous materials should be transported in the trunk, or as far away from passengers as possible.
- All containers should be clearly labeled with content information.
- Materials needed to contain or clean-up a spill, such as sorbent pads, gloves, and eye protection, should be available in the vehicle.
VII. Reusing Boxes that were marked for Hazardous Materials
Packages for hazardous materials may be reused if specific conditions are met. The package, closures, and cushioning materials must be inspected before they are reused to ensure that they contain no incompatible residues and have no structural damage. The packaging must meet all of the general packaging requirements and specification packaging standards.
If the box is being re-used to ship a non-hazardous material, the box must be free of any trace of hazardous materials markings. Any left over labels, parts of labels, or other hazardous material markings should be completely removed or defaced.