Hazardous Material? • Listed in the Hazardous Materials Table, 49 CFR 172.101 Table • Meets the defining criteria for a Hazard Class, 49 CFR part 173 • Materials that are a Hazardous Substance (EPA reg in DOT rule) • Materials that are a Hazardous Waste, EPA RCRA regulated
Who Regulated HM? • US Department Of Transportation • DOT • International Civil Aviation Organization • ICAO • International Air Transport Association • IATA • International Maritime Organization • IMDG • United Nations • UN TDG • Transport Canada • TC – TDG regulations (plain language)
What About My Material? • 1st : CLASSIFY it into a Hazard Class • 2nd : Identify the REQUIREMENTS • 3rd : Identify the EXCEPTIONS • 4th : Do you qualify for the exceptions • 5th : Use the exceptions • 6th : Package the material • 7th : Verify and Transport
172.101 Table, HMT • This is the “Backbone” to the regulations • Start here in Classification • Materials listed by • Technical Name • End Use/Product Name • Generic Chemical/Use Family • Hazard Class Name (requires other classification first)
Multiple Hazard Materials • If your material meets multiple definitions you must: • Identify each Hazard Class/Division • Go to the Precedence of Hazard Table • Found at 173.2a • Determine the PRIMARY HAZARD • Return to the HMT and look for a Hazard Class Name that includes all SUBSIDARY HAZARDS
Multiple Hazard Materials • BE CAUTIOUS • Multiple hazards may remove you or limit you from the Small Quantity Exception Usage • Toxic Subsidiary Hazards may eliminate you • Radioactive materials are not allowed by ANL Policy (consult with the SPM/Shipping Staff)
Small Quantity Exception DOT has an EXCEPTION for small quantities 49CFR173.4 Contains Requirements ANL Exemption to the Transportation Safety Manual more restrictive Special requirements for air shipments in IATA Label/marking, packaging, inner packaging
Quantity Limitations Apply • For 6.1 PG I Maximum per inner container is 1 gram • For all others Maximum per inner container is 30 grams or 30 milliliter • Outer package may contain only one hazard class per package • Maximum package limit is 29 kg (64 lb.)
Tested Packaging is Required • Package that has been tested available from the APS Stock Room • Packages must be tested in configuration used • From 6 feet all packages withstand • 1 drop on top, bottom, long side, short side, • 1 drop onto intersection of 3 corners • Compressive load test required
Special Marking Required • Outside of the package must be marked • “This package conforms to 49 CFR 173.4” • Marking must be • Visible during shipment (not on bottom) • Contrasting color • Durable (withstand 90 days of conditions) • Legible • 1/2” high lettering.
Inner Receptacle Requirements (for Ground Transport ONLY) • Not liquid full at 55degrees C (131 F) • Is plastic at lease 0.2 mm (0.008 inch) thick or glass, earthenware, metal • All removable closures held securely with wire, tape or other positive means • Air Transport packages have additional requirements • Temp range -40 to 131 degrees F • Withstand internal pressure of 95 kPa
Packaging Requirements • Cushioning and absorbent must: • Not react with material • Be capable of absorbing entire contents • Receptacles packed in inner packaging, then placed into outer • Outer package must be sealed, and may not be opened during transportation.
Safety • For all packages received: • Competent person must inspect packages for: • signs of leakage • significant damage to packaging • Must be performed before the package if opened • Use this inspection to verify that all materials have been disclosed to the CAT/beamline group, compare against ESAF • If package is acceptable release to user.
Leaking or Suspect Packages • If package appears to be damaged: • Place package in the nearest fume hood • Be sure there are no incompatibles in the hood • Close sash to fully closed position • Block or close drains • Contact the APS Chemical Hygiene Officer • Contact shipper and user if possible • Verify contents of package from documentation
Leaking or Suspect Packages • If leaking contact 911 for assistance • Notify the Floor Coordinator or the APS Chemical Hygiene Officer • If shipper can provide appropriate information, continue with package inspection • If outer packaging is damaged, but contents are not, release contents to user.
Leaking or Suspect Packages • Packaging and Waste Materials • Treat materials as a Hazardous Waste • Contact EMO-Waste Management for guidance if required or • Contact APS Chemical Hygiene Officer for guidance • If packaging appears contaminated • Move to satellite accumulation area in another container • Mark the container “Suspect Hazardous Waste” • Do not intermingle with other wastes
Leaking or Suspect Packages • Package and Contents Breached • Seek guidance from EMO-Waste Management on disposal • Treat as hazardous waste • Do not attempt to recover materials • May be attempted after appropriate safety review has been completed • Only allowed if appropriately characterized and adequate controls in place • CAT management has authorized work to proceed • Written procedures for recovery may be needed.
Leaking or Suspect Packages • Actions required • CAT management must consult with APS Chemical Hygiene Officer to: • determine investigation requirements • determine reporting requirements • prepare appropriate reports • document the situation and actions taken
TUD-23 Small Quantity Exception Qualifying materials and quantity limits of materials that may be transported to the APS by APS Users. This table applies to ground transport only.
TUD-25 Transport of Cryo-Preserved Biological Samples Authorized Materials
TUD-25 Transport of Cryo-Preserved Biological Samples Allowed dry shippers
User Shipping Summary Who Can Handle Non-Radioactive APS User Shipments 1 Shipping papers shall be addressed as from: User Name, User’s Home Institution, c/o APS Sector ___, 9700 South Cass Avenue, Argonne, IL 60439. 2 If the sender is an ANL employee or if ANL material is being sent then the shipment must be arranged through the ANL Shipping Department. 3 In accordance with the small quantity exception as specified in APS Technical Update 23 (16 July 1998). 4 Air shipment allowed in accordance with the DOT requirements as specified in APS Technical Update 25 (20 May 1999).