49 CFR § 172.700–172.704 (updated Oct. 1, 2006). All individuals who are preparing hazardous materials for shipment must communicate with their institution’s transportation coordinators. Shipment of experimental materials is also discussed in Chapter 11, sections 11.F.1 and 11.F.2.
The use of personal vehicles, company or institutional vehicles (including airplanes), and customer vehicles for transporting regulated materials, which may be hazardous, is a major concern. In many cases, handling regulated materials in this manner is prohibited by DOT or will require shipping papers, placarding, and/or other conditions. Most businesses and academic institutions forbid the use of privately owned personal vehicles, because of the serious insurance consequences if an accident occurs. Most individuals will find that their personal vehicle insurance does not cover them when they are transporting hazardous materials.
Shipping chemicals by air is regulated by IATA. An individual who holds IATA certification must inspect the packaging, review the paperwork, and sign the shipping papers. For domestic shipping by ground or rail, DOT regulations apply and may require a bill of lading or manifest, placarding, special packaging, and other conditions.
Be aware that international transfer of chemicals and research materials is regulated by EPA, the Department of Commerce, and the U.S. Customs Bureau as imports and exports. Federal and international laws strictly regulate domestic and international transport of samples, specimens, drugs, and genetic elements, as well as research equipment, technologies, and supplies—even if the material is not hazardous, valuable, or uncommon. Mail, shipments, and luggage are being screened for these materials. Packages to or from research institutions receive additional scrutiny, as well as any package that appears to contain bottles or liquids.
Chapter 8 describes the requirements for shipping hazardous waste.
5.F.1 Materials of Trade Exemption
DOT has an exception to many requirements for transportation of hazardous materials, referred to as the “materials of trade” (MOT) exemption, which applies to the transportation of small quantities of hazardous materials that are part of your business. Examples include the following:
• facilities maintenance services (i.e., paints and paint thinners for painters and gasoline for groundskeepers),
• researchers (i.e., preservatives for field samples), and
• educational demonstrations (i.e., chemicals for public school outreach education programs).
Under this exemption, it is permissible to transport your own hazardous materials as long as certain conditions are met. These include proper packaging according to DOT requirements. The packaging must be the manufacturer’s original packaging or a package of equal or greater strength and integrity. The packaging must be marked with a common name or a proper shipping name from the Hazardous Materials Table. Other requirements are
• Packagings must be leaktight for liquids and gases, and siftproof for solids.
• Packages must be securely closed, secured against movement, and protected against damage.
• Outer packagings are not required for receptacles (such as cans or bottles) that are secured against movement in cages, bins, boxes, or compartments.
• Cylinders and pressure vessels must conform to DOT’s hazardous materials regulations (49 CFR Parts 171–180) except that outer packagings are not required. These cylinders must be marked with the proper shipping name and identification number and have a hazard class warning label.
• If the package contains a reportable quantity of a hazardous substance, it must be marked “RQ.” Reportable quantities are found in Appendix A of 49 CFR § 172.101.
5.F.2 Transfer, Transport, and Shipment of Nanomaterials
This guidance applies to the movement of material from a laboratory to and from off-site locations. Personnel who package and prepare nanomaterials for shipment off-site must be current on hazardous material employee training required by 49 CFR Part 172, Subpart H. Consult your institution’s shipping department for assistance and routing of your materials. Although the guidelines provided here are for nanomaterials, the procedures are worth considering for shipping any material.
Any nanomaterial that meets the definition of a hazardous material according to 49 CFR § 171.8 and is classified as a hazardous material in accordance with 49 CFR §§ 173.115–173.141 and 173.403–173.436 must be packaged and marked, and labeled shipping papers must be prepared. The package must be shipped in accordance with 49 CFR Parts 100–185 and all applicable regulations.
Any nanomaterial shipped by air that meets the definition of a dangerous good according to the In-