Shipment of Hazardous Material

Amherst College

IATA TRAINING

International Air Transportation Association

United States Department of Transportation (DOT) / Federal Aviation Administration (FAA)

March 2017 

Why do I have to take this training?

-          IATA training is required for any person who has, or may have the responsibility to ship packages which have the potential to contain “dangerous goods” as defined below. These requirements must be followed if shipping of packages is to be done by carriers such as FedEx, UPS, the United States Postal Services or similar shippers.

-          Non-compliance with these regulations are criminal offenses that have the potential for both monetary fines and/or imprisonment for up to five (5) years. In addition to the risk associated with shipping packages that have the potential to cause health and physical harm or death on board an aircraft, the fines for violations of this regulation range from thousands of dollars per day, up to $500,000 if a person from Amherst College ships a “dangerous good” consciously.

-          Penalties could also include loss of privileges to ship “dangerous goods” packages in the future, or having to utilize only certified organizations to receive or ship these packages for Amherst College.

-          Agencies that could levy fines against the College for non-compliance with regard to IATA are not limited to the DOT and FAA. They could also include; the Bureau of Industry and Security (BIS), Federal Motor Carrier Safety Administration (FMCSA), Research and Special Projects Administration (RSPA) and the United States Coast Guard.

  • This specific training program that you are now receiving is required by the Federal Aviation Administration (FAA) to hopefully prevent anyone from shipping a dangerous good by accident.
    • Example – The shipper (you) may assume, given its close proximity to the College that the package you are about to transfer to a carrier is being shipped by ground, which is not often the case. Even packages that are destined for an adjoining state are often transferred by air for carrier cost saving reasons. Ground packages may go by air without our knowledge, so we must be aware that this can occur, and take the necessary steps to prevent an issue of non-compliance.
  • Because your position may be tasked with the responsibility of shipping out a package that could contain a “dangerous good”, you are required to receive IATA training. The penalty for non-compliance with this training component is $50,000. Again, the rationale for the training is to prevent the possibility of having a package shipped by air, or in a manner that would adversely affect the health and safety of person(s) handling or carrying a “dangerous good.”
  • This training is required to be done every two (2) years, as a refresher.

How likely is it that Amherst College could be cited and/or fined for non-compliance with IATA regulations?

         On two separate occasions (approximately 5 years apart), the College came close to being fined $50,000 by the FAA, who discovered during a routine inspection at the FedEx facility in Hatfield, “discrepancies” with paperwork; “red flags” relative to materials being shipped improperly.

  • A package was shipped to Amherst College by mistake, and returned to sender (in Albany NY). When the “dangerous good” left the College (authorized by signature) it was first shipped by air to Louisiana, before being shipped to Albany, again by air.
  • A “dangerous good” package was sent by a college department who initially thought that their department would never have to send a “dangerous good” so they opted out of the initial training years before. As a result, the FAA again came close to levying the $50,000 fine for lack of training.

         What would be a very likely scenario for the College?

  • Imagine something as innocent as shipping a piece of equipment with the battery still attached to it, or gasoline (even a miniscule amount) still in the tank, or a mold sample for analysis. These (3) above referenced incidents resulted in fines for both small and large companies of $60,000, $70,000 and $84,000, respectively.
  • What is a “dangerous good?”

    -  Dangerous goods include, but are not limited to;

    • Air cylinders (including firefighter and laboratory)
    • Alcohol
    • Bacteria and Viruses
    • Batteries (all)
    • Battery Powered Equipment (all)
    • Biohazardous Materials
    • Chemicals (all)
    • Cleaning Agents (all)
    • Containers under any amount of pressure
    • Corrosive Materials (acids and bases)
    • Dry Ice filled Packages
    • Fireworks
    • Flammable Liquids (all)
    • Gas Cylinders (all)
    • Gas Powered Tools
    • Infectious Agents
    • Laboratory Samples (all)
    • Lighters and Matches
    • Magnets
    • Paints (combustible and flammable)
    • Perfumes
    • Plants
    • Radioactive Materials

Not Cleared for Take-Off Poster

 It is the College’s responsibility as the shipper to properly classify, label, mark and package all dangerous goods and hazardous materials in accordance with federal and international governmental regulations.

  • Every known or potential “dangerous good” must be completely evaluated to protect your department and the College from an issue of non-compliance.
    • Does the material being shipped qualify as a known or potential “dangerous good” as referenced in the list above?
      • Is it hazardous?
      • How much is being shipped?
      • Are there any exceptions?
      • How must it be packaged?
        • Package Group I, II or III (most to least hazardous)
      • How must it be labeled?
      • What are the “markings” that must appear on the package?
      • Will placarding be required?
      • What about shipping papers?
  • The regulations that govern the shipping of “dangerous goods” are very complicated. The information referenced above is meant to show the level of detail that is required when shipping a package.

Reasons for IATA fines include;

-          Failure to train person(s), including faculty, staff and students who could or will ship “dangerous goods”

-          Shipping packages that were not properly classified, documented, labeled, marked or packaged for shipment.

-          Failure to provide emergency response information on the appropriate documents/forms

What should you do if you assume/know that the package you need to send by carrier is a “dangerous good?”

-          Amherst College has a shipping program to assist you. It conforms to all of the mandates of the state, federal and international regulatory requirements. The program is carrier specific for each company and satisfies the FAA’s detailed requirements and restrictions.

-          If you would like to have a package shipped that you believe meets the requirements referenced above, or would like to have questions answered with regard to same, please contact;

  • Kristi Evenson-Ohr, Chemical Hygiene Officer (CHO) in the Department of Chemistry
  • Maureen Manning, Safety Officer in the Department of Biology and Neuroscience
  • Rick Mears, Director of Environmental Health & Safety

-          For additional information, please feel free to review the full IATA policy/procedure on the EH&S website.    

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