ternational Civil Aviation Organization (ICAO) must be packaged, marked, labeled, and shipped with an accompanying properly prepared dangerous goods declaration in accordance with the ICAO technical instructions.

Nanomaterials that are suspected to be hazardous (e.g., toxic, reactive, flammable) should be classified, labeled, marked, and manifested as though that hazard exists. These materials should be classified and shipped as samples according to 49 CFR § 172.101(c) (11) unless the material is specifically prohibited by sections 173.21, 173.54, 173.56(d), 173.56(e), 173.224(c), or 173.225(b). These suspect materials should be packaged in accordance with sections 5.F.2.1 and 5.F.2.2, below.

Nanomaterials that do not meet DOT’s criteria listed above may pose health and safety risks to personnel handling the materials if the materials are released during transport. Therefore, all shipments of nanomaterials, regardless of whether they meet the definition for hazardous materials, should be consistently packaged using the equivalent of a DOT-certified packing group I (PG I) container and labeled as described in section 5.F.2.1, below.

5.F.2.1 Off-Site Transport and Shipments of Nanomaterials

This section applies to nanomaterials that are sent to a laboratory and from a laboratory to off-site locations and that do not otherwise meet the DOT definition of hazardous material.

The outer and inner package should meet the definition of PG I–type package. The innermost container should be tightly sealed to prevent leakage of nanomaterials. It should have a secondary seal, such as a tape seal, or a wire tie to prevent a removable closure from inadvertently opening during transport.

The outer package should be filled with shock-absorbing material that can

   protect the inner sample container(s) from damage and

   absorb liquids that might leak from the inner container(s) during normal events in transport.

As depicted in Figure 5.2, the inner package should be labeled (not to be confused with DOT hazard labeling).

If the nanomaterial is in the form of dry dispersible particles, add the following line of text:

Nanomaterials can exhibit unusual reactivity and toxicity. Avoid breathing dust, ingestion, and skin contact.


FIGURE 5.2 Recommended inner packaging label for on-site transfer of nanomaterials.

Documentation and notifications for off-site transfer of nanomaterials should include the following:

   a signed and complete dangerous goods declaration or shipping papers prepared in accordance with ICAO and DOT regulations by certified/qualified hazardous material employees who are authorized to release materials from the site;

   available descriptions of the material (e.g., MSDSs) (researchers should prepare a document for the samples that describes known properties and other properties that are reasonably likely to be exhibited by samples); and

   a notification to the receiving facility of the incoming shipment.

All materials should be transported by a qualified carrier.

   Shipments of nanomaterials classified as other materials (neither recognized HazMat or suspected DOT HazMat) may be transported using the most expeditious method provided they are packaged according to the requirements in section 5.F.1.

   The driver must possess basic hazard information on the commodity being transported, that is, material name, quantity, form, and MSDS if available.

5.F.2.2 On-Site Transfer and Transport of Nanomaterials

The on-site transfer of nanomaterials should follow the site-Specific transportation safety document or other institutional document (i.e., Chemical Hygiene Plan); in lieu of such a document, the transfer should

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