• The shipping of hazardous materials is heavily regulated by the U.S. Department of Transportation and the International Air Transport Association (IATA). The IATA regulations are always equal to or more stringent than the D.O.T. regulations. The IATA regulations govern air transport not only in the US, but worldwide as well.
• The shipping of hazardous materials can pose a serious danger to anyone who might come in contact with the shipment. Therefore, it is critical that one carefully follow the rules so that any possible unsafe condition is minimized. The D.O.T. can and does impose severe penalties that includes huge fines and possible jail time for anyone who knowingly or unknowingly violates these regulations.

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• Identify whether the item being shipped is considered to be hazardous by consulting Title 49 of the Code of Federal Regulations.
• Title 49 of the Code of Federal Regulations, Section 172.101 defines the terms and lists the materials that are denoted as hazardous.
  • If a chemical is not on this list it is not considered hazardous WITH THE FOLLOWING EXCEPTION:
  • If you are synthesizing a new material, the onus is on the researcher to best characterize any possible hazard and to assign a hazard class and Proper Shipping Name. There is help available to the researcher at D.O.T. headquarters in Washington DC. Among the important attributes that this list delineates is the Proper Shipping Name (PSN), the UN number, and the hazard class.

STEP 2 - Is This a Hazardous Substance? Are There Special Provisions?

• If an item is considered a hazardous material, further investigation is necessary.
• Is the shipment large enough to be considered a Hazardous Substance having a �Reportable Quantity?�
• Is the shipment small enough to be defined as a �Small Quantity� and thus qualify for an exception?
• Are there any �Special Provisions� associated with the shipping of this material?
• These terms have very specific meanings.

STEP 3 - Packing Groups and Packaging

• Once all of the items in Steps 1 & 2 are identified and understood, the material must be properly packaged.
• There are three packing groups, each having a different set of criteria.
  • A material assigned to Packing Group l indicates that there is a high degree of danger associated with that chemical.
  • A Packing Group lll designation indicates the least amount of danger considering that it still is a hazardous material.
  • The general packaging requirements are delineated in Section 178 of CFR 49.
• For many items, a simpler resource is the IATA packaging instructions. As was stated, these instructions will always be equal to or more stringent than the D.O.T. regulations. However, since air transport is the most restricted mode of shipping, many materials can only be shipped by ground and, therefore, lack IATA packaging instructions. To review the IATA regulations, please contact Lenny Solomon (solomon@harvard.edu).

STEP 4 - Labeling

• Under most circumstances, packages that contain hazardous materials need to be properly labeled for shipping.
• The label designates the type of hazard the material presents.
• The following are the officially designated hazard categories:
  • 1.1 - EXPLOSIVES 1.1
  • 1.2 - EXPLOSIVES 1.2
  • 1.3 - EXPLOSIVES 1.3
  • 1.4 - EXPLOSIVES 1.4
  • 1.5 - EXPLOSIVES 1.5
  • 1.6 - EXPLOSIVES 1.6
  • 2.1 - FLAMMABLE GAS
  • 2.2 - NONFLAMMABLE GAS
  • 2.3 - POISON GAS
  • 3 - FLAMMABLE LIQUID
  • 4.1 - FLAMMABLE SOLID
  • 4.2 - SPONTANEOUSLY COMBUSTIBLE
    4.3 - DANGEROUS WHEN WET
  • 5.1 - OXIDIZER
  • 5.2 - ORGANIC PEROXIDE
  • 6.1 - POISON INHALATION HAZARD (zone A or B)
  • 6.1 - POISON (other than inhalation hazard)
  • 6.2 - INFECTIOUS SUBSTANCE
  • 7 - RADIOACTIVE WHITE-I
  • 7 - RADIOACTIVE YELLOW-II
  • 7 - RADIOACTIVE YELLOW-III
  • 7 - EMPTY (empty packages of radioactives)
  • 8 - CORROSIVE
  • 9 - CLASS 9
• These categories are explained in Section 172.400 of CFR 49.
• These labels CANNOT be handmade. They have to be purchased from a printing distributor that has manufactured them according to the DOT specifications for size, shape, and color. If you require a label, contact Lenny Solomon (solomon@harvard.edu or 5-4215).
• On occasion, section 172.101 will delineate that a hazardous material will have a primary hazard plus one or more secondary hazards. For example the primary hazard for methyl vinyl ketone (UN1251) is 6.1, it�s poisonous. However, it is also flammable and corrosive. In cases like this, there are definite rules regarding how to label such a shipment.

STEP 5 - Marking

• Under most circumstances, the minimum markings on a shipment of hazardous materials must include:
  • the proper shipping name,
  • the UN number,
  • the consignee's name and address,
  • the consignor's name and address.
• At times there could be other markings such as Fragile, Do Not Tip, Do Not Wet, or Biohazard. All of the rules are delineated in Section 172.300 of CFR 49.

STEP 6 - Placarding

• It is actually both the shipper�s and the trucking company�s responsibility to ensure that the vehicle picking up hazardous material has the appropriate placards displayed on the truck.
• These requirements are delineated in Section 172.500 of CFR 49.
• When shipping hazardous goods, always try to deal with a familiar transportation company.

STEP 7 - Shipping Papers

• In some cases there will be two sets of paperwork associated with a hazardous shipment:
  • the airbill or waybill,
  • a Shipper�s Declaration of Hazardous Goods.
• In other cases, such as when using Fedex, these two forms are combined. The preparation of this paperwork can be found in Section 172.20 of CFR 49.
• A 24-hour emergency telephone number that can be called if there is a crisis must be listed on all of the paperwork. The number to list for Harvard is 617-495-5560, which is the number of the Control Center in the basement of the Science Center. This desk has someone assigned to it 24 hours a day 365 days per year.
• Prior to shipping, one must write a memo to the Control Center stating:
  • what is being shipped including the proper shipping name and UN number,
  • who is shipping it,
  • where it is being sent,
  • your office, lab, and home phone numbers,
  • when you plan to ship it,
  • when it might be scheduled to arrive,
  • the associated MSDS.
• This way, if the truck transporting your hazardous material has an accident, if there is any question regarding the nature of the hazard or its cleanup, you can be contacted.
• This memo must be brought to the Control Center, where it will be posted.

STEP 8 � Summary and Exceptions

The regulations that govern the shipping of hazardous materials are very detailed. The instructions given above are only meant to serve as a guideline and will work for only the simplest of shipments. In the event that the regulations are not clear to you or if your shipment seems to be an exception to some of the rules stated above, please contact Lenny Solomon (solomon@harvard.edu or 5-4215) for help and assistance.

Links

• U.S. Department of Transportation - http://hazmat.dot.gov/rules.htm
• International Air Transport Association (IATA) - http://www.iata.org/dangerousgoods
• DOT Security Plan - Harvard's Response
• EH&S Info - Shipping Dangerous Goods

Created: 22 July 2003