All research materials shipping will be done through UMass EH&S eShip Global
Questions about shipping? Contact EH&S Hazardous Materials Control Manager at: 413-545-2682.
What is a Shipping Paper?
A Shipping Paper is a shipping order, bill of lading, manifest or other shipping document serving a similar purpose and containing the information required by §§172.202 , 172.203 and 172.204 .
What is a HazMat employer?
A HazMat employer is a person who uses one or more of its employees in connection with: transporting hazardous materials in commerce; causing hazardous materials to be transported or shipped in commerce; or representing, marking, certifying, selling, offering, manufacturing, reconditioning, testing, repairing, or modifying containers, drums, or packagings as qualified for use in the transportation of hazardous materials. This term includes an owner-operator of a motor vehicle which transports hazardous materials in commerce. This term also includes any department, agency, or instrumentality of the United States, a State, a political subdivision of a State, or an Indian tribe engaged in an activity described in the first sentence of this definition.
What is a HazMat employee?
A HazMat employee is a person who is employed by a hazmat employer and who in the course of employment directly affects hazardous materials transportation safety. This term includes an owner-operator of a motor vehicle which transports hazardous materials in commerce. This term includes an individual, including a self-employed individual, employed by a hazmat employer who, during the course of employment:
- Loads, unloads, or handles hazardous materials
- Manufactures, tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packagings as qualified for use in the transportation of hazardous materials
- Prepares hazardous materials for transportation
- Is responsible for safety of transporting hazardous materials; or
- Operates a vehicle used to transport hazardous materials.
By going through EH&S will there be a delay in shipping my materials to collaborators?
There should be minimal delays in this process, but they can occur. In general, the better you plan, the easier it will be to get your package out the door. If you follow the procedures, include the necessary paperwork and contact EHS in a timely manner, the shipment should not be delayed. We will do our best to ensure prompt attention but if you have unusual requirements, or unscheduled shipments, the shipment could be delayed. 99% of the shipments should be routine but if you anticipate any unusual request we suggest that you contact us ahead of time for clarification.
How do I know that EHS has shipped my sample? Can I get a record of the shipment?
Except for emergencies, EHS would prefer to package, label and complete the appropriate shipping papers in the laboratory. Once the package is prepared and the declaration is signed the laboratory group will be responsible for scheduling the pickup. In doing so, EH&S is not handling the material, the group will have receipt of shipment and therefore can ensure that the package was picked up by the transporter and can track the package through the carrier's internal systems.
I am concerned that my compound will not be handled properly by EHS. Can I package it myself and give it to you for shipping?
No. All hazardous materials must be packaged, labeled and signed by a certified EH&S hazmat employee. EHS will come to your laboratory and prepare the material for shipment, working with an appropriate member of the laboratory group to ensure the material is properly handled and packaged. It is the responsibility of the individual shipping the compound to convey any time, temperature and/or other sensitive information when working with the UMass EH&S EShip Global program.
I have no idea about my compound. How do I determine its toxicity or other effects?
A researcher should utilize Material Safety Data Sheets (MSDSs) in determining the toxicity or other associated hazards. MSDSs should be included with the materials being shipped if they are available (EHS will retrieve the appropriate MSDS).
For materials which are being synthesized in a laboratory, a TSCA form should be completed and included with the materials being shipped. The Toxic Substance Control Act (TSCA) requires manufacturers of compounds to provide information regarding hazards of newly synthesized items. An R&D exemption exists for laboratory compounds not for commercial use, assuming that the proper certification is in place. In order to maintain this exemption the form provided by EHS must be filled out in its entirety.
What if I send hazardous materials by USPS without stating that they are hazardous materials?
The U.S. Department of Justice will take severe actions against any person or group that willfully violates hazardous materials shipping regulations. The US Department of Justice commented that:
"The government will increase monitoring air cargo shipments and seek to prosecute those who illegally ship hazardous material that officials say could lead to accidents or be used by terrorists. The crackdown will target shippers who hide dangerous materials in otherwise safe cargo, obtain fraudulent licenses to carry hazardous materials or violate a variety of safe transportation practices. Criminal prosecution will be given to those who willfully and flagrantly violate the law."
I only ship small quantities of a compound. Must I go through this process?
Yes. This process must be utilized regardless of quantity.
The DOT and IATA regulations are convoluted. Items which may seem safe in small quantities or may seem non-hazardous may be regulated. A streamlined process is in place to allow EH&S to work with the campus community to evaluate small quantities and less hazardous materials in a timely fashion. If these materials are deemed to be non-hazardous by a qualified EH&S staff member they can be shipped by the PI or the lab group.
Can I complete the Hazardous Materials Declaration forms and send it by FedEx or USPS myself?
No, DOT and, IATA (if shipping by air) regulations are very specific and extensive.
These regulations state that anyone who affects the shipment of hazardous materials is considered to be a "hazmat employee". The regulations require that hazmat employees be trained and certified. The DOT requires that a hazmat employee be trained initially and every three years, or when regulations change, in proper shipping requirements, and be trained initially and refreshed annually in Security Awareness and In-depth Security for hazardous materials shipping. IATA requires that any person shipping hazardous materials by air receive an initial training and refresher training every twenty-four months. Both agencies also require certification be kept on file for trained hazmat employees The potential penalties for violations of DOT and IATA regulations can range from $250,000 per individual to $500,000 per institution apply towards all aspects of shipping a dangerous good.
In order to limit potential liability for improper shipment of hazardous materials, the University has chosen to designate a qualified person (or qualified people) as the Certified Shipper. The Certified Shipper operates out of EH&S (545-2682).
Are all shipments of Dry Ice regulated as hazardous materials?
No, shipments within the United States which utilize 5.07 pounds or less of Dry Ice as a refrigerant are exempt from hazardous materials shipping regulations. The person shipping the materials must use proper packaging and must mark the container with:
- The name of the contents being refrigerated
- The amount of dry ice per package, or an indication that the net weight is less than 5.07 pounds
- The words “Dry Ice” or “Carbon Dioxide, Solid”
Does every hazardous material fall under the purview of the DOT and/or IATA?
No, only hazardous materials being transported "in commerce" are regulated under DOT and IATA guidelines. If a material is being shipped by highway, rail, or ship, the material will be regulated under DOT regulations. If the material is being shipped via air, it will be regulated under IATA regulations. Because most items shipped via air are also transported via highway (FedEx truck, UPS Truck, etc.), DOT regulations would also apply.
What is hazardous material?
A Hazardous Material is any Biological, Chemical or Radioactive material which is defined as being hazardous per the Department of Transportation (DOT) and/or the International Air Transport Authority (IATA). These materials can be found in the DOT Hazardous Materials Table or in the current IATA reference manual. Each item should be reviewed on a case by case basis, as the IATA and DOT lists are quite extensive. Examples of regulated items include:
- infectious substances gases
- genetically modified organisms ignitable materials
- biological products corrosive materials
- diagnostic specimens toxic materials
- medical waste oxidizers, organic peroxidea
- explosives reactives, flammable solids
- radioactive materials environmentally hazardous
If you have any questions or are uncertain about whether your material should be shipped as a hazardous material please contact EH&S Hazardous Materials Control Manager at: 413-545-2682.