CHEMICAL / HAZARDOUS MATERIAL SAFETY
5.40
Revised 3-11
Office of Research Assurances
335-4462
POLICY
University personnel are responsible for complying with applicable federal and state laws and regulations when engaging in the following activities or preparing materials related to the transport and shipment of hazardous materials or dangerous goods:
- Packaging,
- Marking,
- Labeling,
- Preparing documentation,
- Loading,
- Offering materials for shipment.
Likewise, University personnel who engage in the above activities must be properly trained in accordance with this policy.
Applicability
This policy applies to University personnel and students at all WSU locations, including, but not limited to, regional campuses, research stations, extension offices, nursing locations, other WSU-affiliated offices, and non-WSU offices.
Responsible Offices
Those having questions regarding this policy are to contact the applicable office below.
General Hazards, Shipping Information
Contact the Office of Research Assurances; telephone 509-335-4462.
Chemical Hazards
Contact Environmental Health and Safety (EH&S); telephone 509-335-3041.
Biological Hazards
Contact the Biological Safety Officer (BSO); telephone 509-335-9553.
Radiation Hazards
Contact the Radiation Safety Office (RSO); telephone 509-335-8916.
Web References
Department of Transportation (DOT)
Refer to DOT regulations for domestic transport of hazardous materials by rail, air, vessels, and motor carrier at 49 CFR 100-185.
http://www.access.gpo.gov/nara/cfr/waisidx_03/49cfrv2_03.html
International Air Transport Association (IATA)
IATA has established guidelines for the transport of dangerous goods by air. Departments may purchase copies of the guidelines by accessing the following link:
WSU Office of Research Assurances
Definition: Hazardous Material/Dangerous Good
A dangerous good is defined as a substance or material that has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety and property when transported in commerce. Materials that are hazardous to the environment (i.e., hazardous substance, hazardous wastes, and marine pollutants) are also regulated.
For purposes of this policy hazardous materials and dangerous goods are used interchangeably within this document. Hazardous materials include, but are not limited to:
- Laboratory, maintenance, and agricultural chemicals
- Biological agents
- Radioactive materials
- Compressed gases
- Patient specimens
- Dry ice
- Refrigerants and related equipment
- Instruments/equipment that contain hazardous materials
Hazardous Materials Transportation Security Plan (HMTSP)
Certain shipments of hazardous materials, including select agents or large amounts of poisons (DOT Hazard Class 6) may require a security plan. Contact the Office Research Assurances for assistance when applicable.
SHIPPING REQUIREMENTS
Trained Coordinators
Any Washington State University student, staff, or faculty member who intends to offer dangerous goods for transportation or shipment must either be a trained University dangerous goods shipping coordinator or must contact a trained University dangerous goods shipping coordinator for assistance.
The training must be in conformance with 49 CFR 172 Subpart H and include IATA training. See training requirements below.
Coordinator Database
The Office of Research Assurances maintains a database of trained shipping coordinators. Telephone this office at 335-4462 to obtain contact information for trained shipping coordinators.
Coordinators for WSU Locations
Each college or department or other WSU location that offers dangerous goods for shipment is required to ensure that at least one employee is trained as a dangerous good shipping coordinator. The shipping coordinator is responsible for ensuring that the college, department, or WSU location meets all applicable shipping requirements. If a location does not maintain a trained dangerous goods shipping coordinator, the person preparing the shipment must seek the assistance of a trained dangerous goods shipping coordinator when preparing shipments of dangerous goods.
Emergency Response Information
An emergency response telephone number must be provided on shipping papers associated with certain hazardous materials. The telephone number must be monitored 24 hours a day while the hazardous material is in transportation, including storage incidental to transportation. This telephone number must be the number of the person offering the hazardous material for transportation or the number of an agency or organization capable of, and accepting responsibility for providing detailed information concerning the hazardous material.
CHEMTREC
To provide this emergency response contact, WSU maintains a service contract with CHEMTREC (CHEMical TRansportation Emergency Center), a third party vendor that assists emergency responders in dealing with incidents involving hazardous materials in transit.
It is the responsibility of the person packaging the materials for shipping to ensure that certain packages containing hazardous materials lists the proper emergency response telephone contact number.
Contact the Office of Research Assurances for more information or to obtain the CHEMTREC telephone number; telephone 509-335-4462.
EXCEPTIONS
Shipments prepared under the following circumstances are not subject to requirements of this section, other than as noted.
Internal WSU Transport
The transport of hazardous materials by University personnel, either in person or when using University or private vehicles, solely for non-commercial University purposes is exempt from DOT regulations but not this policy.
Transport of hazardous materials by University personnel may only be conducted when the following conditions or requirements are fulfilled:
- Only small amounts or limited quantities are allowed. The maximum net quantity (weight or volume) must be less than the amount allowed on a passenger aircraft (see IATA section 4.2 List of Dangerous Goods, column J).
- The material must be in appropriate, leak-proof containers or packaging.
- Secondary containment is to be used to contain any spill of the hazardous materials being transported.
- Incompatible materials are to be separated into different secondary containers.
- When in a vehicle, hazardous materials are to be transported in the trunk, or as far away from passengers as possible.
- All containers are to be clearly labeled with content information and include applicable Material Safety Data Sheets or precautionary instructions (e.g. warning labels for pesticides, controlled substances, etc.).
- Materials and supplies, including personal protective equipment needed to contain or clean up a spill are to be available in the vehicle.
- Individuals transporting hazardous materials must either carry a method of communication should a spill or release occur or be accompanied by another individual.
- The individual transporting hazardous materials must be trained and familiar with each material's hazards, the precautionary measures to avoid those hazards, and procedures to contain or clean up a spill. It is strongly recommended that individuals new to transporting hazardous materials, or transporting new or different materials consult with EH&S staff to insure they have appropriate knowledge, training, and materials to safely transport hazardous materials.
Radioactive Materials
All outgoing University shipments of radioactive materials or radiation machines must be coordinated through the Radiation Safety Office; telephone 509-335-8916. This requirement applies to all University locations. The Radiation Safety Office handles all aspects of such shipments, including coordination with the transporter.
Shipment of Certain Wastes
Hazardous Chemical Wastes
This section does not apply to hazardous chemical wastes. See 5.66 and 5.68 for procedures for managing hazardous chemical wastes.
Radioactive Wastes
This section does not apply to radioactive wastes. See 9.60 for procedures for managing radioactive wastes. For current guidelines refer to the Radiation Safety Office website at:
Biohazard Wastes
This section does not apply to biohazard waste offered for shipment in commerce. See 4.24 for procedures for managing biohazard wastes. For further information, refer to the Biosafety website at:
Only trained personnel may prepare hazardous material packages for shipment.
The training must be in conformance with 49 CFR 172 Subpart H.
Office of Research Assurances
The Office of Research Assurances arranges and coordinates the training requirements for the University. Contact the Office of Research Assurances to request information regarding training options for both initial and refresher training.
Confirmation of Training
After receiving initial or refresher training, the employee sends the training completion confirmation from the training vendor to the Office of Research Assurances for inclusion in the coordinator database. If training is completed online at the Office of Research Assurances website, training confirmation is provided as part of the training and added to the database.
Refresher Training
The University requires refresher training every two years for all shipping coordinators. It is the responsibility of each department requiring a trained coordinator to monitor and ensure compliance with these requirements. The Office of Research provides refresher training at:
The Office of Research Assurances sends notifications when refresher training is required.
IMPORT/EXPORT
Importing Materials
Persons importing dangerous goods into the United States must provide the shipper and forwarding agent at the place of entry with information regarding the requirements of the Hazardous Materials Regulations (49 CFR Subpart C) applicable to the shipment while in the United States.
Exporting Materials
Persons exporting dangerous goods from the United States must comply with t he common carrier's requirements and any applicable regulations of the foreign country.
NONCOMPLIANCE
Intentional Noncompliance
Intentional disregard or deliberate noncompliance with this University policy by any student, staff member, administrator, or faculty member may result in University corrective or disciplinary action.
Legal Penalties
Failure to comply with 49 CFR may result in penalties for WSU and/or an employee.
WSU may be subject to civil penalties that can range from $275 to $55,000 per violation per day.
Individuals can be subject to criminal penalties for knowing and willing violations. Such penalties can range up to $250,000 and if found guilty, an individual may face up to ten years in prison.
Defense and Indemnification
Whenever a WSU officer, agent, or employee may, as a result of the good faith performance of his or her WSU duties, becomes subject to a lawsuit, claim, action, or proceeding, the law provides that the Board of Regents may authorize the defense of, and payment of all costs of, the proceeding. This includes the costs of any judgment that may arise out of the claim or proceeding. See BPPM 10.15. (RCW 28B.10.842)