Shipping Hazardous Materials
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Policy No.: 2002
Effective Date: 08/10/06
Revised Date: 01/11/13
Reviewed Date: 01/11/13
Shipment of Hazardous Materials or Dangerous Goods Policy
The shipment of hazardous materials or dangerous goods is a serious matter that requires University of Nebraska Medical Center (UNMC) compliance with regulatory requirements. All employees who ship hazardous materials or dangerous goods, which includes dry ice, Category A Infectious Substances affecting humans and/or animals, Category B Infectious Substances (biological substances), patient specimens (exempt human or animal specimens) and cultures, shall follow regulatory requirements for the applicable mode of transportation (e.g., air, ground).
Basis for Policy
The Department of Transportation (DOT) in Title 49 of the Code of Federal Regulations (CFR) provides instructions for all modes of transportation. In addition, the International Civil Aviation Organization (ICAO) and the International Air Transport Association (IATA) impose more stringent requirements for air transportation by providing technical instructions. Violations of these regulations may result in fines ranging from $500 to $32,500 per day per violation.
- Hazardous material is a substance or material which is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated by the DOT. The term includes hazardous substances, hazardous wastes, marine pollutants, and elevated temperature materials as defined, materials designated as hazardous under 49 CFR §§172.101, and materials that meet the defining criteria for hazard classes and divisions in 49 CFR Part 173.
- Dangerous goods means articles or substances which are capable of posing a significant risk to health, safety or to property when transported and are classified by ICAO or IATA as dangerous goods.
- Patient specimens are those collected directly from humans or animals, including but not limited to excreta, secreta, blood and its components, tissue and tissue fluid swabs and body parts, being transported for purposes such as research, diagnosis, investigational activities, disease treatment and prevention
- Cultures are the result of a process by which pathogens are intentionally propagated.
- Exempt human or animal specimens are patient specimens for which there is minimal likelihood that pathogens are present.
- Infectious substances are substances which are known or are reasonably expected to contain pathogens. Pathogens are defined as micro-organisms (including bacteria, viruses, rickettsiae, parasites, fungi) and other agents such as preons, which can cause disease in humans or animals.
- Category A: An infectious substance which is transported in a form that, when exposure to it occurs, is capable of causing permanent disability, life threatening or fatal disease in otherwise healthy humans.
- Category B: An infectious substance which does not meet the criteria for inclusion into Category A. Infectious substances in Category B must be assigned as "Biological Substance, Category B, UN 3373".
- Employees shall not offer for shipment packages containing hazardous materials or dangerous goods until they receive applicable training and ensure that the package complies with regulations. Training may be scheduled by contacting the Environmental Health & Safety Department (ext. 9-6356). Employees are required to receive a certificate upon completion of training.
Note: Transfer or Receipt of Select Agent Organisms or Chemical Toxins
42 CFR Part 73 requires laboratories to be registered by the U.S. Department of Health and Human Services before they can possess, transfer, or receive select agent or organisms or chemical toxins. To comply with this federal mandate, any laboratory considering the transfer or receipt of these agents must first contact the UNMC Biosafety Officer, ext. 9-7774 for guidance on registration and shipment requirements. The list of select agent organisms can be found in Section B-4 of the UNMC Chemical Safety Manual.
- Employees shall meet the initial and recurrent training requirements prior to signing a shipper's declaration or authorizing a hazardous material or dangerous goods package not requiring a shipper's declaration (e.g., dry ice, biological substances. Training shall be in accordance with 49 CFR 172 Subpart H and IATA requirements. Recurrent training is required every two years.
- The point of contact for the proper shipping of hazardous material or dangerous goods is UNMC Environmental Health & Safety Department (9-6356, zip 5480). All correspondence with Federal Aviation Administration (FAA) or DOT shall be through the Environmental Health & Safety Department. Should a FAA or DOT agent arrive on campus, contact the Environmental Health & Safety Department.
- Certified employees may ship packages from departmental locations. All shipments must be packed and shipped by a certified individual.
- The shipper shall review the following for each hazardous material or dangerous goods shipment to ensure compliance with the regulations.
- Applicability to regulations
- Packing specifications and performance tests
- Marking and labeling
- Radioactive material
- Only FAA- or DOT-approved shipping containers, if required, shall be used when specified. Some containers are available in the UNMC Mail Services Department. Individual departments who utilize their own specialized or reusable containers must ensure that the vendor supplies a package performance test certification, if required, for each type of container used, if the material being shipped requires it. The certification must be kept on file by the individual shipper and will be audited for compliance.
- A person who offers a hazardous material for transportation must provide an emergency response telephone number, if required, (including the area code or international access code) for use in the event of an emergency involving the hazardous material.
- UNMC has registered with CHEMTREC to provide an emergency response information. CHEMTREC was founded by members of the Chemical Manufacturers Association and is the nation's premier hazardous material emergency response source. CHEMTREC specialists have access to over 1.5 million MSDSs and can ensure that emergency personnel at the scene of an accident or spill have the assistance they need.
- All shippers will use the CHEMTREC telephone number as the emergency contact number for domestic shipments. The CHEMTREC number is (800) 424-9300.
- If the package is shipped outside the USA then you must also add the international telephone number (703) 527-3887.
- Certified shippers must keep, on file, available for inspection, shipping documentation (air bills, shippers declarations, bill of lading) for two (2) years after the acceptance of the material by the initial carrier. Shippers must also keep current copies of vendor package certifications (if required) in the file for inspection.
- A person who offers a Category A Infectious substance package for transport must follow the special handling security requirements as outlined in UNMC-IBC30. Please consult this policy prior to shipment. For questions regarding this policy, call Peter Iwen at 559-7774.
- The Environmental Health & Safety Department will conduct audits of shippers to verify that all components are being implemented and are adequate. This includes, for example, training, packaging, and proper completion of the shipping papers. Audit findings are documented under a system designed by the Office of the General Counsel for the University of Nebraska to ensure attorney-client privilege. Information resulting from internal audits must not be photocopied or duplicated.