DOT Hazmat

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DOT Hazmat

• Function-Specific Training
• For
• UW Life Science Research

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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.

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What if I get caught?
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Step-By-Step Hazmat Shipping

• Take this class
• Pass the 24/7 phone procedure exam
• Determine who regulates your package CDC, USDA,
  BATF, HHS, DOT...
• If you need an approval prior to shipment, start
  that process.
• After that, if we've already shipped it legally
  once since August 2005, then check my hazmat
  shipping web site for changes in PI650, PI602,
  and IATA Section 3.6.2. If there are no changes
  that affect your shipment, 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.
• You complete packaging, labeling, marking, and
  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.

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CDC Form EA-101
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Select Agent Transfer Form EA-101

• 42CFR 73.14 Transfers.
• A select agent or toxin may not be transferred
  from one entity to another entity within the
  United States (regardless of whether the transfer
  is interstate or intrastate), or received by an
  entity in the United States from an entity
  outside the United States, unless
• (a) The sender
• (1) Has a certificate of registration that covers
  the transfer of the particular select agent or
  toxin to be transferred, (2) Meets the exemption
  requirements under 73.6 (a) for the particular
  select agent or toxin to be transferred, or (3)
  Is transferring the select agent or toxin from
  outside the United States (and all import
  requirements are met)
• (b) The recipient has a certificate of
  registration that includes the particular select
  agent or toxin to be transferred
• (c) Prior to the transfer, the recipient and
  sender completes CDC Form EA101, and the
  recipient submits to the HHS Secretary in
  accordance with 73.21 a completed CDC Form
  EA101.
• (d) CDC has authorized the transfer based on the
  finding that the recipient has a certificate of
  registration covering the transfer of the select
  agent or toxin
• (e) The sender complies with all applicable laws
  concerning packaging and shipping
• (f) The Responsible Official of the recipient
  provides a completed paper copy or facsimile
  transmission of CDC Form EA101 to the sender and
  to the HHS Secretary within 2 business days of
  AFTER receipt of the select agent or toxin and
• (g) The recipient immediately reports to the HHS
  Secretary if the select agent or toxin has not
  been received within 48 hours after the expected
  delivery time, or if the package received
  containing select agents or toxins has been
  leaking or was otherwise damaged.
• (h) When the select agents or toxins are consumed
  or destroyed after a transfer, the recipient must
  within five business days report such fact to the
  HHS Secretary in accordance with 73.21 on a CDC
  Form EA101.
• How does the sender know whether the recipient RO
  has submitted Form EA-101?

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Biological Products are regulated by HHS under 42
CFR, but not by IATA.

• IATA "3.6.2.1.2 Biological products are those
  products derived from living organisms which are
  manufactured and distributed in accordance with
  the requirements of appropriate national
  authorities, which may have special licensing
  requirements, and are used either for prevention,
  treatment, or diagnosis of disease in humans or
  animals, or for development, experimental or
  investigational purposes related thereto. They
  include, but are not limited to, finished or
  unfinished products such as vaccines".
• IATA 3.6.2.3.1(a) ... "transported for the
  purposes of final packaging or distribution, and
  use for personal health care by medical
  professionals or individuals. Substances in this
  group are not subject to these Regulations".
• No researcher at University of Wyoming would be
  shipping Biological Products.

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Q Is purified DNA or RNA a hazardous material
for shipping purposes?

• JLS Non-infectious DNA and RNA are "Not
  Restricted" in the U.S., even if genetically
  modified. Genetically modified organisms are
  regulated outside the United States as Class 9,
  but are not yet regulated within the United
  States.

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IATA 3.6.2

• 3.6.2 Division 6.2Infectious Substances
• OPERATOR VARIATIONS AF-04, FX-09, LA-07, LH-12
• Go to handout IATA3.6.2.20050705.pdf

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Dangerous Goods List
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Packing Instruction 602for UN 2900and UN 2814
Go to PI602text.pdf (available on my web site)
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DGD Form required for Category A, not Category B.
Category A Criteria Exposure capable of
causing permanent disability or death in
otherwise healthy humans or animals.
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PI 650 Biological Substance Category B
If it's infectious to humans or animals, but
not Category A, then it is Category B. Go to
PI650.pdf
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Minimum Packaging Requirements

• Three layers, plus absorbent and padding.
• Primary containment strong enough to withstand
  atmospheric pressure and temperature variations,
  with positive mechanism to prevent cap from
  unscrewing.
• Absorbent sufficient for 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.

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UW Shipping Request Form
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FedEx Airbill
6. Special Handling Mark "Yes" or "No" to
indicate whether your shipment contains Dangerous
Goods. If yes, as per attached shippers
declaration, include two copies of a Shippers
Declaration for Dangerous Goods.
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Q How are shipping papers for the helium and
nitrogen dewars handled?

• RMMC staff will try to provide the service of
  transporting dewars between the Molecular Biology
  Animal Science bldg and the Chemical Stock Room
  in the Physical Sciences bldg.
• If you transport the dewar yourself, call the
  RMMC first. You need shipping papers to
  transport a dewar in a University vehicle. If
  you transport it in your personal vehicle, you
  have no liability coverage.
• Because they own their own dewars, the BOC Gases
  company generates shipping papers for return of
  dewars to BOC from the Physical Sciences loading
  dock, for example. Some, but not all, other gas
  suppliers provide this same courtesy.
• If your supplier delivers to, and picks up from,
  Shipping Receiving, SR will demand a shipping
  paper from the carrier who delivers the dewar to
  SR, before delivering the dewar to you. You
  should get a copy of that shipping paper. SR
  will demand a shipping paper from you, to return
  your empty dewar to SR. You can simply modify
  the incoming shipping papers for transport back
  to SR, or edit a copy of our UW generic shipping
  paper, to create a shipping paper for return to
  SR.

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Q I'm shipping a material that is not regulated.
Do I have to ship my package as hazmat if the
only hazardous material in it is dry ice?

• JLS Yes, but you do not need a Dangerous Goods
  Declaration.
• You need the Class 9 label for the dry ice. SR
  will provide that label if you fill out their
  shipping request form.
• The text marking on the outside of the box must
  state
• Dry Ice, UN1845
• and the original weight of dry ice in kg. SR
  will mark the weight of dry ice on the label for
  you.
• Do not seal the box with tape so well that the
  CO2 gas can't escape.
• SR will complete the carrier's air way bill
  "Nature and Quantity of Goods" box with
• Proper Shipping Name "Dry Ice"
• Hazard Class 9
• UN number UN 1845
• If you have over-packed several packages
• Net quantity per package
• Number of packages

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Excepted Quantities
Shipping regulated materials as Excepted
Quantities is easy. All you need is an Excepted
Quantity label no DGD, no special markings,
no other labels, and non-spec packaging. It is
forbidden to ship infectious materials as
Excepted Quantities.
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Q I have a few micrograms of CWD prion
immobilized on a slide, to ship by air without
dry ice for investigational purposes. Am I
exempt from DOT regs?

• JLS You must determine whether your material is
  regulated. There is no de minimis quantity below
  which your material is no longer regulated.
• If it is infectious, it is regulated.
• If your package is inspected, it would be best if
  the inspector agrees with your determination.

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Q I have a few micrograms of CWD prion
immobilized on a slide, to ship by air without
dry ice for investigational purposes. Am I
exempt from DOT regs?

• Category A Requires a DGD and label, and you
  probably want UN specification packaging to
  comply with PI 602. Read PI 602 available on
  my web site.
• Category B You need sturdy packaging and the new
  UN 3373 label to comply with PI 650. Read PI 650
  available on my web site.
• Genetically modified organisms transported
  outside the U.S. are regulated as Class 9.
• If not infectious and no other hazard class
  applies, it is NOT RESTRICTED.

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The Beginning

• Call us weeks before you get stuck.
• 766-3697
• Try my "Shipping Hazardous Materials" web site on
  the EHS web site.