Shipping Dangerous Goods at the University of Virginia Shipping Dangerous Goods at the University of Virginia (Even More Fun Than It Sounds) Adam P. Peters Hazardous Materials Program Manager, University of Virginia

UVA Fun Facts Charlottesville, VirginiaCharlottesville, Virginia Founded in 1819 by Thomas JeffersonFounded in 1819 by Thomas Jefferson ~15,000 Undergrads,~15,000 Undergrads, ~6,000 Graduate Students ~6,000 Graduate Students ~1,800 Labs~1,800 Labs Hospital: 604 bedsHospital: 604 beds

UVA (continued) Large Quantity GeneratorLarge Quantity Generator 90 Day90 Day Waste Facility opened in 1985; expanded twice since.Waste Facility opened in 1985; expanded twice since. Shipped ~140,000# of Hazardous Waste and ~60,000# Non-HazShipped ~140,000# of Hazardous Waste and ~60,000# Non-Haz Pick Up ~1,400 containers/monthPick Up ~1,400 containers/month

Shipping UVA -- Origins In 2001 I was asked to develop a program to train people to ship infectious substancesIn 2001 I was asked to develop a program to train people to ship infectious substances –I gave in person training sessions and also developed an online training module. –I Presented on the subject at the 2002 CUHWC. –I also offered to ship I.S. for people. Word started to get out.

Eventually Somebody Wondered “I have this chemical I need to ship. If I need to be trained to ship infectious substances, does that mean I need to be trained to ship this?”“I have this chemical I need to ship. If I need to be trained to ship infectious substances, does that mean I need to be trained to ship this?”

She Told Two Friends, and They told Two Friends… In April 2003 I got a call asking to help with the shipment of a compressed gas cylinder.In April 2003 I got a call asking to help with the shipment of a compressed gas cylinder. –Went to lab—packed and shipped from there. In May 2003 another D.G. request came in.In May 2003 another D.G. request came in. Then several in June.Then several in June. Apparently this was not a passing fad.Apparently this was not a passing fad.

I Developed a Program I ship from my office, not the person’s lab/office.I ship from my office, not the person’s lab/office. I acquire packaging, unless they already have something suitable.I acquire packaging, unless they already have something suitable. I use FedEx.I use FedEx. Bill shipping charges to lab, either by using their FedEx account number or billing back.Bill shipping charges to lab, either by using their FedEx account number or billing back.

Call Comes In “I have this chemical I need to ship (by tomorrow, today if possible).”“I have this chemical I need to ship (by tomorrow, today if possible).” Okaaaaaaay…Okaaaaaaay…

What I Ask First What is it?What is it? How much?How much? Where is it going?Where is it going? –Domestic? Overseas? –Are we in a hurry? Ground? Air?Ground? Air?

What Is It? And, more importantly, is it regulated? Some things not regulated by ground, are by air % Formalin solutions: UN 3334, Aviation regulated liquid, nos, % Formalin solutions: UN 3334, Aviation regulated liquid, nos, 9 Sodium iodide: UN 3077 Environmentally hazardous substance, nos, 9Sodium iodide: UN 3077 Environmentally hazardous substance, nos, 9 Dry Ice, 9Dry Ice, 9

How Much? Excepted Quantity? Limited Quantity? Mass Quantities? “Do you really need to send that much?”

Excepted Quantity

9 Lab Dude 17 University Drive Charlottesville, VA 22901

Training Requirements IATA Training Curricula Personnel must be trained in the requirements commensurate with their responsibilities Personnel must be trained in the requirements commensurate with their responsibilities Training must include Training must include –(a) General familiarization –(b) Function specific –(c) Safety

Excepted Quantity Requirements Closure of inner packaging must be secured by positive secondary means.Closure of inner packaging must be secured by positive secondary means. Inner packaging must be placed in an intermediate packaging which is packed with cushioning material.Inner packaging must be placed in an intermediate packaging which is packed with cushioning material. Liquids must be packed with absorbent material.Liquids must be packed with absorbent material. Intermediate packaging must be packed in strong rigid outer packaging.Intermediate packaging must be packed in strong rigid outer packaging. The completed excepted quantity mark (in color) must be applied to outside of packageThe completed excepted quantity mark (in color) must be applied to outside of package “Dangerous Goods in Excepted Quantities” must be included on bill of lading or air waybill.“Dangerous Goods in Excepted Quantities” must be included on bill of lading or air waybill.

Limited Quantity? Packaging requirements are, but really aren’t more relaxed.Packaging requirements are, but really aren’t more relaxed. Will not incur a Hazardous Materials $urcharge.Will not incur a Hazardous Materials $urcharge.

Where To? Domestic? Overseas?Domestic? Overseas? One if by Ground? Two if by Air?One if by Ground? Two if by Air?

Packaging

TSCA Research Exempt Must be in small quantities solely for R&D.Must be in small quantities solely for R&D. The chemical substance must be used by, or directly under the supervision of, a technically qualified individual.The chemical substance must be used by, or directly under the supervision of, a technically qualified individual. The manufacturer must notify the persons to whom it distributes the chemical substance, by means of a container labeling system and written notification, that the substance is to be used only for research purposes, and of health risks which the manufacturer has reason to believe may be associated with the substance.The manufacturer must notify the persons to whom it distributes the chemical substance, by means of a container labeling system and written notification, that the substance is to be used only for research purposes, and of health risks which the manufacturer has reason to believe may be associated with the substance.

TSCA Research Exempt (cont) 1.Complete Reserch Exempt Substances Notification Form. 2.Label each individual sample “For R&D use only.” 3.Sign RESN Form and make two copies. 4.Place one COPY in package with samples. 5.Retain one COPY in lab’s records. 6.Send original form to EHS to be retained for 5 years.

Training DOT vs. IATADOT vs. IATA DOT—every 3 yearsDOT—every 3 years IATA—every 2 yearsIATA—every 2 years

Dry Ice! In 2008 a UVA employee shipped Dry Ice improperly resulting in a $30,000 fine.In 2008 a UVA employee shipped Dry Ice improperly resulting in a $30,000 fine. –I was asked to develop a Dry Ice training module.

Down the Rabbit Hole

Instead of Buying Packaging

49 CFR Reuse… of packagings § 49 CFR Reuse… of packagings Packagings used more than once must: (a) Must be inspected and in good condition(a) Must be inspected and in good condition (b)(1) Must not show reduction in integrity(b)(1) Must not show reduction in integrity (b) (2) (i)Packagings subject to the leakproofness test shall be retested in accordance with (b) (2) (i)Packagings subject to the leakproofness test shall be retested in accordance with §

Reuse (cont.) § (a)(2) This test is not required for inner packagings of combination packagings.§ (a)(2) This test is not required for inner packagings of combination packagings. So we’re good, right? There are no separate performance standards for reused packaging.

§ Shipper’s responsibility: (a) A person may offer a hazardous material for transportation in a packaging required by this part only in accordance with: (2)The person shall determine that the packaging is an authorized packaging… in accordance with: (i)Section 173.7(a) & parts 173, 178 or 179 of this subchapter

§178, Subpart M Testing of Non-bulk Packagings § — Preparation of packagings and packages for testing.§ — Preparation of packagings and packages for testing. § — Drop test.§ — Drop test. § — Leakproofness test.§ — Leakproofness test. § — Hydrostatic pressure test.§ — Hydrostatic pressure test. § — Stacking test.§ — Stacking test. § — Vibration standard.§ — Vibration standard.

§ Shipper’s Responsibility (a)(4)(i) a person must perform all functions necessary to bring the package into compliance with parts 173 & 178 of this subchapter (for example, applying closures consistent with the manufacturer’s closure instructions) Closure instructions?

§ Shipper’s Responsibility (a)(4)(ii) a person must retain a copy of the manufacturer's notification, including closure instructions. …A copy of [which] must be made available for inspection by a representative of the department (DOT) upon request for at least 90 days once the package is offered for transportation…

IATA All inappropriate DG markings and labels must be obliterated before reuse.All inappropriate DG markings and labels must be obliterated before reuse. Note: Not all packages are intended to be re- used for shipment of DG. When package meets the conditions of and may be re- used, the shipper must have access to the information required by Blah, blah, blah, you can’t re-use it!

The End