Hazardous Material Transportation

Policy

No employee of the University of Chicago shall prepare for, offer or accept international, interstate, or intrastate transportation of a hazardous material except in accordance with criteria set forth in this policy and procedure.

Employees seeking information on International Air Transport Association (IATA) regulations should contact Environmental Health and Safety for assistance at 773.702.9999.

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Authority and Responsibility

Departments with employees affected by this program are responsible for:

  1. Purchasing materials required for the proper transportation of hazardous materials;
  2. Utilizing shipping papers for inter-campus transport of hazardous materials, if applicable; and
  3. Providing proper placards to motor vehicle carriers, if applicable.

Environmental Health and Safety is responsible for:

  1. Reviewing and amending the overall Hazardous Materials Transportation Program;
  2. Conducting DOT General Awareness training;
  3. Conducting DOT In-Depth Security training for essential personnel;
  4. Conducting Shipping Infectious Substances training; and
  5. Maintaining all training records.

Employees are responsible for:

  1. Completing all required training for shipping hazardous materials; and
  2. Complying with all aspects of this program.

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Hazardous Material Classifications and Divisions

Under the Hazardous Materials Transportation Program, there are 11 hazard classes (nine numbered and two unnumbered) – classes 1 through 9, divisions plus the classes Combustible Liquids and Other Regulated Materials (ORM).

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Packaging

Each hazardous material is assigned to one of three packing groups (PG I, PG II, PG II) based on the degree of danger presented by the material either great, medium, or minor respectively.  Each packing group has specific container packaging requirements based on tests for dropping, leakage, etc.  If more than one packing group is indicated for an entry, the packing group for the hazardous material is determined using the criteria for assignment of packing groups specified for each class in 49 Code of Federal Regulations (CFR) 173 Subpart D. Class 2, Class 6.2, Class 7 and ORM-D materials, do not have packing groups. All packing groups are specified in column 5 of the 172.101 Hazardous Materials Table. Contact Environmental Health and Safety at 773.702.9999 for copies of the table.

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Marking/Labeling

General Marking

All markings on the outside of a hazardous material package must be durable, easy to read, in English and unobstructed by anything else on the package.

Marking for Non-Bulk Packaging

The outside of each non-bulk package and any inside containers of hazardous materials must be marked with the following information:

  1. Proper shipping name;
  2. Identification number (preceded by “UN” or “NA”, as appropriate); and
  3. Name and address of the consignee or the consignor (the consignee is the person to whom the package is sent. The consignor is the person who sends the package except when the package is transported by highway only and will not be transferred from one motor carrier to another; or part of a carload lot, truckload lot or freight container load, and the entire contents of the rail car, truck or freight container are shipped from one consignor to on consignee.

Identification numbers are not required on packages which contain only limited quantities or ORM-D materials.

When a non-bulk package contains inner containers of hazardous liquid materials, the inner containers must be packed with the caps/lids upright. In addition, it must be legibly marked with package orientation markings on two opposite vertical sides of the package with the arrows pointing in the correct upright direction. Arrows for purposes other than indicating proper package orientation may not be displayed on a package containing a liquid hazardous material.

For materials poisonous by inhalation, the package shall be marked “Inhalation Hazard” in association with the required labels or placards. Each non-bulk plastic outer packaging used as a single or composite packaging for materials meeting the definition of 6.1 shall be permanently marked, by embossment or other durable means, with the word “POISON” in letters at least 6.3 millimeters (0.25 inch) in height. The marking shall be located within 150 millimeters (6 inches) of the closure of the packaging.

If the package contains the reportable quantity of a hazardous substance, the letters “RQ” must be marked in association with the proper shipping name. Reportable quantity means the quantity specified in column 2 of the Hazardous Materials Table for any material identified in Column 1 of the table.

Table 2 of the Hazardous Materials Table lists materials which are considered to be Marine Pollutants or Severe Marine Pollutants. If a material is considered to be a Marine Pollutant or Severe Marine Pollutant and will be transported by vessel, the package must be marked accordingly.

Marking for Bulk Packaging

Bulk packages are required to display the proper shipping name on two opposite sides. The “UN” or “NA” identification number shall be displayed on each side and each end if the packaging has a capacity of 3,785 liters (1,000 gallons) or on two opposing sides if the packaging has a capacity of less than 3,785 liters (1,000 gallons).

For bulk packaging containing materials poisonous by inhalation, the package shall be marked “Inhalation Hazard” on two opposing sides in association with the required labels or placards.

Labeling

Each package containing hazardous materials presented for transportation must be labeled with a hazard label(s) that corresponds to the hazard class of the material it contains. Hazard labels must be placed on the same side of the package as the proper shipping name and “UN” or “NA” identification number markings. These labels must be clearly visible and unobstructed by anything else on the package. Column 6 of Hazardous Materials Table indicates the required label for each material listed.

Hazard warning labels must meet strict Department of Transportation (DOT) guidelines regarding size, shape, color and content. Domestic labels will generally have words; however, labels used in international commerce may be wordless.

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Placarding Motor Vehicles

49 CFR 172.504 below lists those hazard classes which require placards for motor vehicles regardless of the amount of material is being hauled as well as the hazard classes which may require placards for motor vehicles depending on the amount material being hauled.

Placarding Exceptions

Considerations to the exceptions can be found in 49 CFR 172.504.

Prohibited Placarding

Other signs or devices which by color, design, shape or content could be confused with required placards shall not be displayed or affixed on any motor vehicle transporting hazardous materials.

Subsidiary Hazards

Placarding for subsidiary hazards is only required for materials that have a DANGEROUS WHEN WET(4.3) or POISON INHALATION HAZARD.  In addition any shipments of Uranium Hexafluoride in excess of 454kg (1001 pounds) would require a CORROSIVE placard in addition to the primary RADIOACTIVE placard.

Refer to 49 CFR 172.504 for more information.

Visibility and Display of Placards

It is the responsibility of the shipper to offer the required placards to the carrier when the carrier loads the hazardous materials for transport. Refer to 49 CFR 172.504 for more information.

NOTE:  If you have questions concerning placarding please contact the Environmental Health & Safety office at safety@uchicago.edu .

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Loading and Unloading

Any tank, barrel, drum, cylinder, or other packaging, not permanently attached to a motor vehicle, which contains any Class 3 (flammable liquid), Class 2 (gases), Class 8 (corrosives), Division 6.1 (poisonous), or Class 7 (radioactive) material must be loaded in such a manner as to secure against movement within the vehicle during transportation.

The Hazardous Materials Regulations contain Segregation Tables 49 CFR 177.848 which indicate the hazardous materials that may not be loaded, transported, or stored together. Materials which are in packages that require labels, in a compartment within a multi-compartment cargo tank or in a portable tank are subject to the Segregation Tables. In addition, cyanides or cyanide mixtures may not be loaded or stored with acids.

Cylinders

Containers with valves or other similar fittings shall be loaded so that there is minimum likelihood of any damage to them during transportation. Cylinders containing Class 2 (gases) materials shall be loaded onto a flat floor or platform of a motor vehicle. In order to prevent the overturning of cylinders, all cylinders must be

  • securely lashed in an upright position
  • loaded into racks securely attached to the motor vehicle
  • packed in boxes or crates of such dimensions as to prevent their overturning
  • or loaded in a horizontal position

Cylinders for hydrogen or cryogenic liquid may only be transported on a motor vehicle which has an open body equipped with a suitable rack or support having means to hold the cylinder upright when subjected to acceleration in any horizontal direction and any motor vehicle carrying such material may not enter a tunnel.

Shipping Papers

All hazardous materials transported in commerce are required to be accompanied by shipping papers. Shippers may use bills of lading, manifests, or way bills as long as these documents contain the required information. The shipping paper requirements do not apply to materials, other than hazardous wastes, hazardous substances, or marine pollutants. 

  • Hazardous materials identified by the letter “A” or in column 1 of the 172.101 – Hazardous Materials Table, that will also be shipped by air, require a description of the hazardous materials on the shipping papers. 
  • Hazardous materials identified by the letter "W" in column 1 of the 172.101 - Hazardous Materials Table that will be shipped by vessel require a description of the hazardous materials on the shipping papers
  • Hazardous materials classed as ORM-D that will also be shipped by air require a description of the hazardous materials on the shipping papers

The shipping papers must be legible and printed or typed in English. No unauthorized codes or abbreviations may be used. A shipping paper may consist of more than one page, if each page is consecutively numbered and the first page bears a notation specifying the total number of pages included in the shipping paper (for example, “Page 1 of 4 pages”).

The following five items must appear on shipping papers containing hazardous materials:

1. A basic description consisting of four elements in the following sequence:

  • UN or NA identification number;
  • Proper shipping name;
  • Hazard class or division: and
  • Packing group number;

2. Total quantity except for empty packaging, cylinders for Class 2 (compressed gases) materials, and bulk packaging, the total quantity (by net or gross mass, capacity, or as otherwise appropriate), including the unit of measurement, of the hazardous material covered by the description (e.g., “800 lbs” or “208 L”) must appear on the shipping paper. For cylinders of Class 2 (compressed gases) materials and bulk packaging, some indication of total quantity must be shown (e.g., “10 cylinders” or “1 cargo tank”);

3. Emergency Number: A 24-hour emergency response telephone number must be reference on the shipping papers.  The University has a subscription with Chemtrec to provide emergency response information.  Chemtrec's contact number is 800.424.9300.

4. Certification Statement: The shipper certifies that the materials listed on the shipping papers have been properly classified, described, packaged, marked and labeled, and are in proper condition for transport according to the regulations established by DOT; and

5. Signature: The signature of the shipper or his agent signifies that the shipment is in compliance with all relevant regulations.

Additional information may be required depending on the contents being transported. Refer to 49 CFR 172.202 and 172.203 for specifics.

Inner-Campus Transport

Transportation of hazardous chemicals made by the Physical Sciences Division (PSD), such as from the Gordon Center for Integrative Sciences (GCIS) loading dock to other campus laboratory buildings, shall use the Shipping Papers for Inner-Campus Transport.  Upon completion of each delivery of hazardous materials, PSD shall scan the shipping papers and submit as an email attachment to Environmental Health and Safety.

General Entries

When a description of a hazardous material is required to be included on a shipping paper with other materials not subject to the requirements of this section, the description for the hazardous materials must conform to at least one of the following requirements:

  • The hazardous material description entries must be entered first;
  • The hazardous material description entries must be entered in a color that clearly contrasts with any description on the shipping paper of a material not subject to the requirements of this section (Except: A description on a reproduction of a shipping paper may be highlighted, rather than printed, in contrasting color); and
  • The hazardous material must be identified by the entry of an “X” placed before the proper shipping name in a column captioned “HM”.

The basic description must be shown in sequence with no additional information interspersed. For example: “UN 1203, Gasoline, 3, PG II” (Identification Number, Shipping Name, Hazard Class, Packing Group).

Exceptions

A list of exceptions can be found at 49 CFR 172.202.

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Emergency Response Information

All hazardous material shipments (except those that do not require shipping papers) must have emergency response information on or accompanying the shipping paper. All emergency response information must legible and in English. The information on or accompanying the shipping paper must be in the form of the Emergency Response Guidebook, a material safety data sheet, or any other form that provides all the following information:

  • The basic description and technical name of the hazardous material;
  • Immediate hazards to health;
  • Risks of fire or explosion;
  • Immediate precautions to be taken in the event of an accident or incident;
  • Immediate methods for handling fires;
  • Initial methods for handling spills or leaks in the absence of fire; and
  • Preliminary first aid measures.

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Hazardous Waste Shipments

A carrier shall not accept a shipment of hazardous waste unless it is accompanied by a properly prepared uniform hazardous waste manifest. Transportation of hazardous waste shall only be conducted by a contractor as provided by Environmental Health and Safety.

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Transportation of Nanomaterials

Nanomaterials that are being transported shall be packaged using the equivalent of a DOT-certified Packing Group I container, regardless of whether they meet the definition for hazardous materials or not.

The inner package shall be labeled “Caution: Nanomaterials sample consisting of (technical description here). Contact (name of point contact) at (contact number) in case of container breakage.” If the nanomaterial is in the form of dry dispersible particles, add the following line of text: “Nanoparticles can exhibit unusual reactivity and toxicity. Avoid breathing dust, ingestion, and skin contact.”

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Training and Information

General Employee Training

Environmental Health and Safety shall provide a training program for employees who during the course of employment directly affect hazardous materials transportation through one or more of the following activities:

  • Loads, unloads, or handles hazardous materials;
  • Tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packaging as qualified for use in the transportation of hazardous materials;
  • Prepares hazardous materials for transportation;
  • Signs hazardous materials waste manifests; or
  • Operates a vehicle used to transport hazardous materials.

The training will be conducted within 90 days of employment for those employees whose job functions involve any of the aforementioned hazardous material tasks and once every two years thereafter. Exception: Additional training shall be provided within 90 days of any job change involving the use of hazardous materials.

An employee may perform job functions prior to the completion of training provided the employee performs those functions under the supervision of a properly trained and knowledgeable employee.

A comprehensive training program shall include the following:

  • General training to provide awareness and familiarization of the requirements of the Hazardous Materials Transportation Program and to enable the employee to recognize and identify hazardous materials consistent with the hazard communication standard;
  • Function-specific training applicable to the functions the employee performs;
  • Safety training pertaining to the following:
  1. Emergency response information;
  2. Measures to protect the employee from the hazards associated with hazardous materials to which they may be exposed in the workplace, including specific measures the employer has implemented to protect employees from exposure; and
  3. Methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials; or
  4. Any additional department specific training (e.g., Pre-trip safety inspection or the use of vehicle controls and equipment, including the operation of emergency equipment).
  5. All employees engaged in the act of shipping infectious substances shall be trained on doing so through additional, function-specific training requirements. Infectious materials are regulated under both IATA and DOT regulations if shipped by air. Contact Environmental Health and Safety at 773.702.9999 for assistance or for copies of the IATA regulations.

Training Records

Training records shall be maintained by Environmental Health and Safety and include the following:

  • The employee’s name;
  • The most recent training date;
  • A description, copy, or the location of the training materials used to meet the aforementioned training requirements;
  • The name and address of the person providing the training;
  • Certification that the employee has been trained and tested as required; and
  • Results of the learning measurement exercise.

All employees attending training shall be required to demonstrate adequate knowledge retention as shown through a learning measurement exercise. Employees not demonstrating adequate knowledge retention shall be retrained and retake the exercise until adequate retention is demonstrated. The passing criteria for the learning measurement exercise is 70 percent.

Reviewed: June 2014

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