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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.