Hazardous Materials Shipping Policy for Laboratories

Transcription

1 Responsible University Official: Responsible Office: Office for Research Safety Origination Date: September 1, 2011 Policy Statement Hazardous Materials Shipping Policy for Laboratories In order to ensure compliance with all regulations governing transportation of hazardous materials, all University faculty, staff, and students who work in laboratories and intend to ship hazardous materials from the University shall follow the procedures established in this policy. Reason for Policy/Purpose Transportation of hazardous materials is regulated by numerous government agencies and non-government organizations, including the United States Department of Transportation (USDOT), the International Civil Aviation Organization (ICAO), and the International Air Transport Association (IATA). Shipping hazardous materials using one of the transportation modes (i.e., via plane, train, highway, or vessel) requires understanding and complying with these regulations. Shipping regulations require that the employer train, test, and certify that the hazardous materials employee, in this case the shipper, is familiar with applicable regulations, safety, security awareness, and can properly identify, classify, package, mark, label, and document each hazardous materials shipment. Failure to meet these regulations has potential public safety implications and each violation of a regulation may result in the following: individual civil penalties up to $50,000 per violation, per day, willful individual violators may be fined up to $250,000 and/or receive up to 5 years in prison, 10 years under special circumstances, and the University may also be fined up to $500,000 per incident. Centralizing the process for shipping certain hazardous materials through the Office for Research Safety (ORS) not only helps ensure compliance with these regulations, it also lessens the burden on researchers who would otherwise require extensive training and decreases the risk to the University. Also, requiring shippers of biological materials to complete ORS-provided training will meet regulatory training requirements and minimize risk to the University. Page 1

2 Table of Contents Page # Policy Statement. 1 Reason for Policy/Purpose.. 1 Table of Contents 2 Who Approved This Policy.2 Who Needs to Know This Policy 2 Website Address for This Policy 2 Contacts/Responsibilities 3 Definitions...3 Policy/Procedures 4 Forms/Instructions...6 Appendices.. 6 Related Information 6 History/Revision Dates... 7 Who Approved This Policy The Vice President for Research approves this policy. This policy must be reviewed by the Chemical and Laboratory Safety Committee (CLSC), Institutional Biosafety Committee (IBC), and the Radiation Safety Committee (RSC). Who Needs to Know This Policy This policy applies only to Northwestern University faculty, staff, and students working in laboratories. They are thereon referred to as laboratory workers. Others shall follow the guidelines of their administrative units or employers. University policies regarding Materials Transfer Agreements of proprietary hazardous materials may also apply. Contact the Office for Sponsored Research any time proprietary materials are being shipped. Website Address for this Policy This policy will be posted and the program will be established at the following address: Page 2

3 Contacts If you have any questions on the policy or procedure for Hazardous Materials Shipping Policy for Laboratories, you may: 1. Call the Manager, Research Safety Training at , or the Laboratory Safety Specialist, Chemistry at Send an to Definitions Biological materials: Code of Federal Regulations (CFR): Certified Hazardous Materials Shipper: Contract Shipper: Dangerous Goods: Dangerous Goods Regulations (DGR): Biological materials include all hazardous materials in hazard class 6.2, genetically modified organisms and genetically modified microorganisms in hazard class 9, and other exceptions described in CFR (b). General and permanent rules and regulations that are published in the Federal Register by United States Federal Government executive departments and agencies. 49 CFR codifies the rules and regulations established by the Department of Transportation. A link to 49 CFR is available in Related Information below. A person who has successfully fulfilled the regulatory requirements to ship hazardous materials. Laboratory workers who ship biological materials and/or dry ice must complete ORS-provided training to become certified hazardous materials shippers. ORS staff is the certified hazardous materials shipper for all other hazardous materials. An ORS-approved company that a laboratory worker can pay to ship hazardous materials. A contract shipper may be used if the established ORS processing time is inadequate to make your shipment on time. Articles or substances which are capable of posing a risk to health, safety, property or the environment and which are listed in the List of Dangerous Goods in the IATA Dangerous Goods Regulations. Hazardous materials (as defined by USDOT) are considered dangerous goods when transported via air. This is the set of regulations established by the International Air Transport Association (IATA). In order to ship dangerous goods, shippers must comply with these regulations or risk refusal to ship via air. Hazard Class: The category of hazard as defined in the CFR 49 Part 173. Page 3

4 Hazardous Materials: Hazardous Materials Regulations: International Air Transportation Association (IATA): Laboratory workers: Shipping: A substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has designated as hazardous under section 5103 of Federal hazardous materials transportation law (49 U.S.C. 5103). The term includes hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials designated as hazardous in the Hazardous Materials Table (see 49 CFR ), and materials that meet the defining criteria for hazard classes and divisions in 49 CFR Part 173. Hazardous materials regulations (HMR) are codified in Title 49 Code of Federal Regulation (CFR). Regulations related to dangerous goods shipments are issued by ICAO and IATA. IATA is an international trade body representing airlines and couriers. It established the Dangerous Goods Regulations (DGR). University faculty, staff, or students who work inside laboratories. The preparation of the hazardous materials package (including marking and labeling) and shipping paper so the package can be offered to a carrier in commercial transportation. The movement from the origin to the consignee is considered carriage. The HMR terms for shipping and carriage generally apply to the transportation of hazardous materials in commerce. Transportation of limited quantity hazardous materials, as defined by USDOT, by a private individual in a private motor vehicle for personal use is not commercial transportation. Policy/Procedures Shipping Biological Materials Laboratory workers who intend to ship biological materials (see definitions above) or dry ice must complete ORS-provided training in order to become certified hazardous materials shippers. ORS will not ship these materials. Page 4

5 Shipping Chemicals Laboratory workers who intend to ship chemicals in the hazard classes listed below must follow the instructions on the Intent to Ship Chemicals Form (see Forms/Instructions) complete and submit it along with a Material Safety Data Sheet (MSDS) for the chemical to ORS: Class No. Division No. (if any) Name of class or division 49 CFR reference for definitions 3 Flammable and combustible liquid Flammable solid Spontaneously combustible material Dangerous when wet material Oxidizer Organic peroxide Poisonous materials Corrosive material Miscellaneous hazardous material None Other regulated material: ORM-D Laboratory workers who intend to ship the following hazard classes must contact ORS directly for instructions. ORS will not ship these classes and will provide instructions for using a contract shipper or other means: Class No. Division No. (if any) Name of class or division 49 CFR reference for definitions None Forbidden materials None Forbidden explosives Explosives (with a mass explosion hazard) Explosives (with a projection hazard) Explosives (with predominately a fire hazard) Explosives (with no significant blast hazard) Very insensitive explosives; blasting agents Extremely insensitive detonating substances Flammable gas Non-flammable compressed gas Poisonous gas Following submission of the Intent to Ship Chemicals Form, ORS shall review the form and contact the laboratory worker regarding any additional required information. ORS shall provide the laboratory worker with instructions to purchase packaging required by the regulations. After laboratory workers obtain the packaging, they shall contact ORS to schedule a lab visit to package their hazardous materials. ORS shall complete the package, mark, label, and sign off on the Shipper s Declaration of Dangerous Goods. ORS shall determine the appropriate courier to deliver the package and instruct the laboratory worker on completing the airway bill and providing payment for transportation costs. Page 5

6 Laboratory workers may use a contract shipper for chemicals if the established ORS processing time of seven (7) business days is inadequate to deliver the shipment on time. A list of contract shippers is provided on the ORS website. Shipping Radioactive Materials All shipments of hazardous materials in Class 7 (Radioactive Materials) must be prepared by trained members of the Office for Research Safety (ORS) staff. For international shipments, selection of a carrier, routing considerations and customs issues are the responsibility of the requestor. For all shipments (foreign or domestic), ORS will package, mark, and label each container and certify on a dangerous goods declaration (if required) that each container is in compliance with applicable regulations. Laboratory workers must complete the Intent to Ship Radioactive Materials form and it to radiationsafety@northwestern.edu with intent to ship in the subject line. A member of the ORS radiation safety staff will contact you to schedule a time to bring the materials to be shipped to the Research Safety office. A tracking number will be provided to you once the package has been prepared and shipped. PLEASE NOTE: All domestic shipments containing radioactive materials are shipped via FedEx; the lab must provide a chart string that is suitable for FedEx shipments. Contract shippers may NOT be used for shipments of radioactive materials. Lab workers intending to ship radioactive materials must ship through ORS. Shipping Program Responsibilities ORS shall maintain the contract for a 24-hour hazardous materials emergency response contact. ORS shall act as the primary contact for hazardous materials shipping-related regulatory inspections. Forms/Instructions Intent to Ship Chemicals Form: Intent to Ship Radioactive Materials Form: Hazardous Materials Contract Shippers: Appendices Not Applicable. Related Information The following agencies or regulations govern the shipment of hazardous materials: Page 6

7 Department of Transportation (USDOT) The Pipeline and Hazardous Materials Safety Administration under the USDOT establish the Hazardous Materials Regulations which govern transport of hazardous materials via highway, rail, vessel, or air. These regulations cover the classification, packaging, hazard communication, emergency response, and training requirements for hazardsous materials shipments. International Air Transport Association (IATA) IATA established the Dangerous Goods Regulations for safe shipment of dangerous goods by air. International Civil Aviation Organization (ICAO) ICAO is a United Nations body which maintains the Technical Instructions for the Safe Transport of Dangerous Goods by Air. Public Health Service (USPHS) Import of etiologic agents is governed by the USPHS 42 Code of Federal Regulations - Part 71 Foreign Quarantine. Part Etiologic agents, hosts, and vectors. For information about import permits, please visit the Etiologic Agent Import Permit Program (EAIPP) on the Center for Disease Control website. History/Revision Dates Origination Date: Month, Day, Year Last Amended Date: Month, Day, Year Next Review Date: Month, Day, Year Page 7