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1. What is a Hazardous Material? 2. Does every Hazardous Material fall under the purview of the DOT and/or IATA? 3. Are all shipments of Dry Ice regulated as hazardous materials? 4. Can I complete the Hazardous Materials Declaration forms and send it by FedEx or USPS myself? 5. I only ship small quantities of a compound, must I go through this process? 6. What if I send hazardous materials by USPS without stating that they are hazardous materials? 7. I have no idea about my compound. How do I determine its toxicity or other effects? 9. How do I know that EH&S has shipped my sample. Can I get a record of the shipment? 10. By going through EH&S will there be a delay in shipping my materials to collaborators? 11. What is a HazMat Employee ? 12. What is a HazMat Employer ? 13.
What is a Shipping Paper ? HHazMat SH A Hazardous Material is any Biological, Chemical or Radioactive material which is defined as being hazardous per the Department of Transportation (DOT) and/or the International Air Transport Authority (IATA). These materials can be found in the DOT Hazardous Materials Table or in the current IATA reference manual. Each item should be reviewed on a case by case basis, as the IATA and DOT lists are quite extensive. Examples of regulated items include:
Should you have any questions or are uncertain about whether your material should be shipped as a hazardous material please contact EH&S for assistance (545-2582). Top 2. Does every hazardous material fall under the purview of the DOT and/or IATA? No, only hazardous materials being transported "in commerce"
are regulated under DOT and IATA guidelines. If a material is being
shipped by highway, rail, or ship, the material will be regulated under
DOT regulations. If the material is being shipped via air, it will be
regulated under IATA regulations. Because most items shipped via air
are also transported via highway (FedEx truck, UPS Truck, etc.), DOT
regulations would also apply. ____________________________________________________________________________________ 3. Are all shipments of Dry Ice regulated as hazardous materials?
No, shipments within the United States which utilize 5.07 pounds or less of Dry Ice as a refrigerant are exempt from hazardous materials shipping regulations. The person shipping the materials must use proper packaging and must mark the container with:
Top 4. Can I complete the Hazardous Materials Declaration forms and send it by FedEx or USPS myself? No, DOT and, IATA(if shipping by air) regulations are very specific and extensive. These regulations state that anyone who affects the shipment of hazardous materials is considered to be a "hazmat employee". The regulations require that hazmat employees be trained and certified. The DOT requires that a hazmat employee be trained initially and every three years, or when regulations change, in proper shipping requirements, and be trained initially and refreshed annually in Security Awareness and In-depth Security for hazardous materials shipping. IATA requires that any person shipping hazardous materials by air receive an initial training and refresher training every twenty-four months. Both agencies also require certification be kept on file for trained hazmat employees The potential penalties for violations of DOT and IATA regulations can range from $250,000 per individual to $500,000 per institution apply towards all aspects of shipping a dangerous good. In order to limit potential liability for improper shipment of hazardous materials, the University has chosen to designate a qualified person (or qualified people) as the Certified Shipper. The Certified Shipper operates out of EH&S (545-2582). Top
5. I only ship small quantities of a compound, must I go through this process? This process must be utilized regardless of quantity. The DOT and IATA
regulations are convoluted. Items which may seem safe in small quantities
or may seem non-hazardous may be regulated. A streamlined process is
in place to allow EH&S to work with the campus community to evaluate
small quantities and less hazardous materials in a timely fashion. If
these materials are deemed to be non-hazardous by a qualified EH&S
staff member they can be shipped by the PI or the lab group. ____________________________________________________________________________________ 6. What if I send hazardous materials by USPS without stating that they are hazardous materials? The US Department of Justice will take severe actions against any person or group that willfully violates hazardous materials shipping regulations. The US Department of Justice recently commented that; "The government will increase monitoring air cargo shipments and seek to prosecute those who illegally ship hazardous material that officials say could lead to accidents or be used by terrorists. The crackdown will target shippers who hide dangerous materials in otherwise safe cargo, obtain fraudulent licenses to carry hazardous materials or violate a variety of safe transportation practices. Criminal prosecution will be given to those who willfully and flagrantly violate the law." ____________________________________________________________________________________ 7. I have no idea about my compound. How do I determine its toxicity or other effects? A researcher should utilize Material Safety Data Sheets (MSDSs) in
determining the toxicity or other associated hazards. MSDSs should be
included with the materials being shipped if they are available (EH&S
will retrieve the appropriate MSDS). For materials which are being synthesized
in a laboratory, a TSCA form should be completed and included with the
materials being shipped. The Toxic Substance Control Act (TSCA) requires
manufacturers of compounds to provide information regarding hazards
of newly synthesized items. An R&D exemption exists for laboratory
compounds not for commercial use, assuming that the proper certification
is in place. In order to maintain this exemption the form provided by
EH&S must be filled out in its entirety. ____________________________________________________________________________________ 8. I am concerned that my compound will not be handled properly by EH&S. Can I package it myself and give it to you for shipping? No, all hazardous materials must be packaged, labeled and signed by a certified EH&S hazmat employee. The EH&S department will come to your laboratory and prepare the material for shipment, working with an appropriate member of the laboratory group to ensure the material is properly handled and packaged. It is the responsibility of the individual shipping the compound to convey any time, temperature and/or other sensitive information on the intent to ship form. EH&S will be especially responsive to these request. ____________________________________________________________________________________ 9. How do I know that EH&S has shipped my sample. Can I get a record of the shipment? Except for emergencies EH&S would prefer to package, label and complete the appropriate shipping papers in the laboratory. Once the package is prepared and the declaration is signed the laboratory group will be responsible for scheduling the pickup. In doing so, EH&S is not handling the material, the group will have receipt of shipment and therefore can ensure that the package was picked up by the transporter and can track the package through the carrier's internal systems. Top There should be minimal delays in this process, but they can occur. In general, the better you plan, the easier it will be to get your package out the door. If you follow the procedures, include the necessary paperwork and contact EH&S in a timely manner, the shipment should not be delayed. We will do our best to ensure prompt attention but if you have unusual requirements, or unscheduled shipments, the shipment could be delayed. Ninety nine percent of the shipments should be routine but if you anticipate any unusual request we suggest that you contact us ahead of time for clarification.
11. What is a HazMat employee
? ____________________________________________________________________________________ ____________________________________________________________________________________ |
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