Environmental Health & Safety

Compliance with DOT and IATA Regulations

January 2010

Shipping of Hazardous Materials

  • Shipping of hazardous materials is regulated by the U.S. Department of Transportation (DOT) and the International Air Transport Association (IATA). The IATA regulations govern air transport not only in the US, but worldwide as well. Amherst College faculty/staff shipping or receiving hazardous materials or dangerous goods must be properly trained in IATA / DOT policies and procedures.
    • The required frequency of IATA / DOT training is every 2 years
  • Shipping hazardous materials can pose danger to anyone who may come into contact with the shipment. Therefore it is critical to follow the rules and regulations, so that any unsafe condition is minimized or eliminated. The (DOT) and (IATA) both impose severe penalties that includes huge fines and possible jail time for anyone who knowingly or unknowingly violates these rules and regulations.

Classification / Identification

It is the shipper’s responsibility: including classification / identification, packaging, marking and labeling hazardous materials or dangerous goods according to all national and international governmental regulations.

  • Identify whether the item being shipped is considered to be hazardous by consulting Title 49 of the Code of Federal Regulations.
  • Definitions, terms and the materials that are denoted as hazardous can be viewed at [Title 49 of the Code of Federal Regulations, Section 172.101.]
    • If a chemical is not on this list, it is not considered hazardous with the following exception:
      • If you are synthesizing a new material, it is the responsibility of the researcher to best characterize or identify any possible hazard and to assign a hazard class and proper shipping name.

Question: Is this a Hazardous Substance?

  • If the chemical/component is hazardous material, further investigation will be necessary.
  • Is there enough of the material being shipped to be considered a hazardous substance having a reportable quantity?
  • Is there a small enough amount of the material being shipped to be defined as a small quantity, qualifying the shipment for an exeption?
  • What if any “special provisions” exist in regard to the shipping of this material?

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 regarding hazardous material.
    • Packing Group l indicates that there is a high degree of danger associated with that chemical.
    • Packing Group ll falls between Packing Groups l and lll and is considered to have some danger associated with that chemical, not as severe as l but not as minimal as lll.
    • Packing Group lll designation indicates the least amount of danger considering that it still is a hazardous material.

Labeling

  • 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:
    Dangerous Goods

    • 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 or created. They have to be purchased from a printing distributor that has manufactured them according to the DOT specifications for size, shape, and color.
  • On occasion, section 172.101 will delineate that a hazardous material will have a primary hazard plus one or more secondary hazards. For example if a chemical's primary hazard is flammable/ignitable, the secondary hazard could be corrosive or reactive as well. In cases like this, there are definite rules regarding how to label and package such a shipment.

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.

Placarding

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

Shipping Papers

  • In some cases there will be two sets of paperwork associated with a hazardous shipment:
    1. Airbill or Waybill,
    2. Shipper’s Declaration of Hazardous Goods.
  • In other cases, such as when using Fedex, these two forms are combined.
  • A 24-hour emergency telephone number that can be called if there is a crisis must be listed on all of the paperwork. The emergency phone number for Amherst College is (413)-542-2111 (Amherst College Campus Police). The Amherst College Campus Police is staffed 24 hours a day, 365 days per year.
  • Prior to shipping, one must write a memo to the Campus Police 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 it's cleanup, you can be contacted.
  • This memo must be brought to the Control Center, where it will be posted.

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. I you have any questions or concerns regarding a potential shipment, policies/procedures or your shipment seems to be an exception to some of the rules stated above, please contact: Richard Mears [ramears@amherst.edu] ext 8189, Kristi Ohr [kohr@amherst.edu] ext 2736 or Maureen Manning [mgmanning@amherst.edu] ext 8328 for help and assistance.

Links

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