Washington State University
SAFETY POLICIES AND PROCEDURES MANUAL

CHEMICAL / HAZARDOUS MATERIAL SAFETY
5.40
Revised 3-11
Office of Research Assurances
509-432-3869

Transport and Shipment of Hazardous Materials and Dangerous Goods

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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:

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 509-432-3869.

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:

http://www.iata.org/publications/dgr/Pages/index.aspx

WSU Office of Research Assurances

http://www.ora.wsu.edu

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:

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 509-432-3869 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 509-432-3869.

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:

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:

http://www.rso.wsu.edu/

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:

http://www.bio-safety.wsu.edu/biosafety

TRAINING

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:

http://myresearch.wsu.edu

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)