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DOT Hazmat

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Title: DOT Hazmat


1
DOT Hazmat
  • Function-Specific Training
  • For
  • UW Research Labs

2
Common Questions
We can skip any that don't interest the students
in each class, until we get to the pages with
yellow background.
3
What if I get caught?
4
Q How much training is actually required by law?
  • 49 CFR 172.704 Training requirements.
  • (a) Hazmat employee training shall include the
    following
  • (1) General awareness/familiarization training.
    ...
  • (2) Function-specific training. ...
  • (3) Safety training. ...
  • (b) OSHA or EPA Training. ... may be used to
    satisfy the training requirements in paragraph
    (a) ...
  • (c) Initial and recurrent training --
  • (1) Initial training. A new hazmat employee, or a
    hazmat employee who changes job functions may
    perform those functions prior to the completion
    of training provided --
  • (i) The employee performs those functions under
    the direct supervision of a properly trained and
    knowledgeable hazmat employee and
  • (ii) The training is completed within 90 days
    after employment or a change in job function.
  • (2) Recurrent training. A hazmat employee shall
    receive the training required by this subpart at
    least once every three years.
  • (3) Relevant Training. Relevant training received
    from a previous employer or other source may be
    used to satisfy the requirements of this subpart
    provided a current record of training is obtained
    from hazmat employees' previous employer.

5
Step-By-Step Hazmat Shipping
  • Take this class
  • Pass the 24/7 phone procedure exam
  • After that, if we've already shipped it legally
    once, then do whatever you did before.
  • Otherwise, determine whether your material is
    regulated by DOT or IATA. Call me a week in
    advance, or three weeks in advance if shipping
    across an international border. You don't have
    the time, interest, training, experience,
    professional contacts, or reference books to make
    the determination, package, mark, label,
    document, and ship a regulated material that you
    have not shipped previously.
  • I will need to know whether you intend to ship by
    air or ground, the exact chemical name, quantity
    and units, current container(s), destination
    address/name/phone, refrigeration requirements,
    and an MSDS if available. I will locate and
    provide to you the correct references to
    classify, identify, package, label, mark, and
    document your shipment.
  • When you understand, agree, complete, and sign
    your shipping papers, then forward the
    documentation to me. I will complete
    documentation needed for UW Police Dispatch, and
    give you a receipt from Dispatch.
  • Complete the Shipping and Receiving Shipping
    request form, and call them to pick up your
    package. Do not transport it yourself.
  • Give your package, shipping papers, and a copy of
    the receipt from Dispatch to Shipping and
    Receiving.

6
Minimum Packaging Requirements
  • Primary containment strong enough to withstand
    atmospheric pressure and temperature variations,
    with positive mechanism to prevent cap from
    unscrewing.
  • Absorbent sufficient for one primary container
  • Secondary containment, e.g. deflated Ziploc.
  • Cushioning that will not fail when wet or when
    dry ice sublimates.
  • Fibreboard box closed with packaging tape.

7
UW Shipping Request FormExample
8
Airbill or Air Way Bill (SR does this for you).
9
Excepted Quantity
  • You can ship one ml of a novel toxic sample as an
    Excepted Quantity
  • in sturdy non-spec packaging
  • without other labels or markings,
  • without a DGD,
  • and without a 24/7 phone number.
  • Drop testing is required.

X
UN 2810
10
Packing Instruction Y611(2003)
11
Packaging Instruction Example
  • Let's assume that you ship in a heat-sealed
    strong glass ampule larger than one ml capacity,
    inside an aluminum tube with a screw top.
  • Your glass ampule is limited to 500ml.,
  • max quantity of liquid in the package is 2 L,
  • and gross weight of the completed package is
    30kg.
  • You are required to have absorbent and cushioning
    and an outer packaging, such as a fiberboard box.
    If the ampule did break, there should be
    absorbent sufficient to absorb all of the liquid.
  • Your absorbent should be contained by something
    other than the cardboard box, perhaps within a
    ziplock bag that contains the liquid vial -
    unless there is a possibility of a reaction
    between liquid and absorbent.
  • Remember that your ampule may experience extreme
    changes in temperature and pressure, and don't
    forget the afternoon soccer break in shipping and
    receiving.

12
Q I have a mildly toxic pharmaceutical compound
to ship by air without dry ice for
investigational purposes. It's a small quantity.
Am I exempt from DOT regs?
  • JLS Could your chemical be non-toxic? Check the
    DOT toxicity criteria in 49 CFR or IATA or in my
    summary sheet. If your material is less toxic
    than this, you have a nonhaz package, and you are
    exempt from DOT regulation. If tox data is not
    available, then toxicity, and therefore the
    packing group, is going to be based on your
    expert judgement and the criteria.

13
DOT Toxicity Criteria
  • FOR LIQUIDS WITH TOXIC VAPORS
  • o 6.1 Packing Group I
  • Zone A LC50 lt 200ppm
  • and saturation (max) concentration in air gt 500
    LC50
  • Zone B LC50 lt 1000ppm
  • and saturation (max) concentration in air gt 10
    LC50
  •  
  • o 6.1 Packing Group II
  • LC50 lt 3000ppm and
  • saturation (max) concentration in air gt LC50
  •  
  • o 6.1 Packing Group III
  • LC50 lt 5000ppm and
  • and saturation (max) concentration in air gt 0.2
    LC50
  • FOR SOLID AND LIQUID TOXICS WITHOUT TOXIC VAPORS
  • o 6.1 Packing Group I
  • o Oral LD50 lt 5mg/kg
  • o Dermal LD50 lt 40mg/kg l
  • o Inhalation LD50 lt 0.5mg/kg particulate
  • o Cyanides, strychnine
  •  
  • o 6.1 Packing Group II
  • o Oral LD50 lt 50mg/kg
  • o Dermal LD50 lt 200mg/kg
  • o Inhalation LD50 lt 2mg/kg particulate
  • o Phenols, nicotine
  •  
  • o 6.1 Packing Group III
  • o Oral LD50 lt 200mg/kg solid,
  • o Dermal LD50 lt 1000mg/kg
  • o Inhalation LD50 lt 10mg/kg particulate
    Pesticides, disinfectants

49 CFR 173.133
14
It's toxic. Now what?
  • If you're still reading, then you probably
    determined that your material is toxic and you
    know its packing group. Your package may still
    qualify for Limited Quantity or Excepted Quantity
    classification. The major advantages are that
    Ltd. Qty. relieves you of the requirement for UN
    specification packaging, and Excepted Quantity
    relieves you of the shipper's declaration of
    dangerous goods and the 24/7 phone number. See
    my summary on Limited and Excepted Quantities for
    details.

15
Advantages of Ltd.Qty. and Excepted Quantity
New FedEx airbill does not have a "Nature of
Goods" box, so you don't have to fill it out.
16
Research Pharmaceutical Example
  • Let's assume that your material is a PG III for
    toxicity.
  • Therefore, your Hazard Class is 6.1, toxic.
  • Check the Hazardous Materials Table in 49 CFR or
    IATA. If your material doesn't appear on the
    HMT, and is not forbidden (check both lists), you
    must use a generic name based on characteristics.
    You might have this as your proper shipping name
  • Toxic liquid, organic, n.o.s. (Phosphonic acid,
    2-piperidinyl-, diphenyl ester, hydrochloride)
  • Note that you must spell and punctuate the proper
    shipping name completely and correctly. Note also
    that there is no comma after "n.o.s.". Also,
    when you use a generic "n.o.s." shipping name,
    you are required to append the parenthetical
    technical name to the generic name, unless it's a
    controlled substance and disclosure is prohibited
    by other regulation. It would be permissible to
    start the parenthetical technical name on the
    line below the generic shipping name.

17
Basic Description
  • Toxic liquid, organic, n.o.s.
  • (Phosphonic acid, 2-piperidinyl-, diphenyl ester,
    hydrochloride),
  • 6.1, UN 2810, III
  • The ERG for this material is 153. Omit the ERG
    unless a space is provided for additional
    handling information.
  • Let's assume that you cannot ship as an Excepted
    Quantity due to a lack of the Excepted Quantity
    label or an excess of material, but you still
    qualify for Ltd. Qty. There is exemption from
    some regs, but it doesn't get you much.
  • You don't have to use UN spec packaging,
  • but if you stacked identical packages to a height
    of 3m, your bottom package should be strong
    enough not to fail,
  • and your package should withstand a four-foot
    drop onto a hard floor.
  • and your packaging is specified by a "Y" packing
    instruction.

18
Marking Labeling the Pharmaceutical Example
  • Mark the proper shipping name and UN number on
    the package. Put them on one side, upper left,
    name on top, technical name below in parentheses,
    UN number right below.
  • Place a haz class 6 "Toxic" label on your
    package.
  • Mark the text "Ltd. Qty." in the lower left edge
    of the side that has the label and proper
    shipping name. If a DOT inspector were to notice
    the label and not see a UN spec packaging code on
    the cardboard box, you might get a call.
  • Place orientation arrows on two sides of your
    package, if have a liquid inside.

19
Limited Excepted Quantities in Soporific Detail
We can skip slides that don't interest the
students in each class, until we get to the page
with yellow background, again.
20
Ltd. Qty. Allowed and Disallowed
21
Excepted Quantities Allowed and Disallowed
22
Quantity Criteria for Excepted Quantities
23
Excepted Quantities Summary pg 1
  • EXCEPTED QUANTITY
  •               Now let's assume that you have a
    "Dangerous Goods in Excepted Quantities" label
    available from your helpful Hazmat staff right
    here on campus.
  • o    Verify that your material
  •       is division 6.1 PG II or III, (not 6.2,
    infectious)
  •       or is division 6.1 PG I, but not due to
    inhalation toxicity.
  • o    You are shipping air freight, not as mail or
    carry-on baggage.
  • o    Your individual vials contain
  •       PG III less than 30 gm or 30 ml,
  •      except if the material has a subsidiary
    risk in addition to its toxicity, in which case
    the vials must contain less than 1 gm or 1 ml.
  •       PG II or I less than 1 gm or 1 ml
  • o    Your overall package contains less than
  •       PG I 300 ml or 300 gm
  •       PG II 500 ml or 500 gm
  •       PG III 1 L or 1 kg
  • See next page

24
Excepted Quantities Summary pg 2
  • o    Your individual containers may be thick
    plastic, glass, earthenware, or metal. Screw
    caps must have secondary mechanical fastening,
    such as tape or wire.
  • o    Your packaging need not be US specification,
    and may be previously used, but is sturdy, has
    three layers, and adequate absorption.
  • o    Put your Excepted Quantities label on one
    side of the package, and addresses on another.
  • o    If the air way bill has a "Nature and
    Quantity of Goods" box, enter "Dangerous Goods in
    Excepted Quantities". But the FedEx form
    probably will not have this box, and you won't
    need to do this.
  • o    Ship it. No DGD required. No 24/7 phone
    required.

25
Step-By-Step Hazmat Shipping
  • Take this class
  • Pass the 24/7 phone procedure exam
  • Then when you have a package to ship, if we've
    already shipped it legally once, since March
    2003, do whatever we did before.
  • Otherwise, determine whether your material is
    hazmat per DOT. Call me. You don't have the
    time, interest, experience, professional
    contacts, or reference books to do this, unless
    it is a common solid material that obviously does
    not meet the criteria for any of the 9 classes.
  • If it is hazmat, and you haven't called me
    already, call me. Give me the Exact chemical
    name, Quantity and units, Current container(s),
    Destination, Refrigeration required, and an MSDS
    if available. I will look for specific
    exceptions, limited quantity exceptions, excepted
    quantity exceptions, specific packaging
    requirements, and current regulatory definitions.
    Again, you don't have access to this
    information.
  • I will tell you how to package, label, mark, and
    document your material, and will provide the
    applicable regulatory references and instructions
    upon request. I will provide packaging materials
    and labeling if required, but there may be a
    charge.
  • Package, label, mark, and document your material,
    then sign the shipping papers.
  • Forward documentation to me. I will complete
    documentation for Dispatch, and give you a
    receipt from Dispatch.
  • Give your package to Shipping and Receiving.

26
The Beginning
  • Call me when you get stuck.
  • 766-3698
  • Try my "Shipping Hazardous Materials" web site on
    the EHS web site.
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