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Hello Everyone,

I just attended a workshop at Oklahoma University that discussed U.S.
hazmat regulations for shipping.  I often ship vials of specimens that
contain small quantities of ETOH, so I asked for some specific direction
about what is required to ship specimens according to proper protocol.  I
want to share the most important parts here with everyone.

I know that this is an international list, so please be aware that this
covers regulations outlined by the U.S. Department of Transportation.  It
also applies only to shipping vial ground.  Shipping by air or waterway has
more or less stringent regulations.

We are able to use regulation 49 CFR 173.4b to exempt us from labeling and
transporting material as hazardous material.  If you follow these
regulations for the exemption, you can ship without declaring your material
as hazardous.  This can be less expensive and prevent unnecessary delays
for shipping.

Here is the direct, applicable excerpt from regulation part 173.4b(b):

(b) Non-infectious specimens, such as specimens of mammals, birds,
amphibians, reptiles, fish, insects and other invertebrates containing
small quantities of Ethanol (UN1170), Formaldehyde solution, flammable
(UN1198), Alcohols, n.o.s. (UN1987) and Isopropanol (UN1219) are not
subject to the requirements of this subchapter provided the following
packaging, marking and documentation provisions, as applicable, are met:
 (1) The specimens are:
 (i) Wrapped in a paper towel or cheesecloth moistened with alcohol or an
alcohol solution and placed in a plastic bag that is heat-sealed. Any free
liquid in the bag must not exceed 30 mL; or
 (ii) Placed in vials or other rigid containers with no more than 30 mL of
alcohol or alcohol solution. The containers are placed in a plastic bag
that is heat-sealed;
 (2) The bagged specimens are placed in another plastic bag with sufficient
absorbent material to absorb the entire liquid contents inside the primary
receptacle. The outer plastic bag is then heat-sealed;
 (3) The completed bag is placed in a strong outer packaging with
sufficient cushioning material that conforms to subpart B of part 173
<http://www.law.cornell.edu/cfr/text/49/173>;
 (4) The aggregate net quantity of flammable liquid in one outer packaging
may not exceed 1 L; and
 (5) The outer package must be legibly marked “Scientific research
specimens, 49 CFR 173.4b <http://www.law.cornell.edu/cfr/text/49/173.4b>
applies.”


Here are a couple of things that need mentioned.  Part (ii) regulates that
each inner vial cannot contain more than 30 ml of ETOH.  Part (4) regulates
that net quantity of flammable liquid may not exceel 1L.  What this means
is that you can have any number of vials, so long as no vial contains more
than 30 ml of ETOH, and that the net amount of ETOH is less than 1L - you
can ship using this exemption.

You MUST print on the outer package, verbatum, part 5 "Scientific research
specimens, 49 CFR 173.4b <http://www.law.cornell.edu/cfr/text/49/173.4b>
applies.”

The rest of the regulation is fairly straightforward about the minimum
regulations for shipping.  It's always okay to go beyond the minimum
requirements to protect packages.  The shipper is responsible for packing
the shipment and you can be held accountable if hazardous material is
released from the package, even if minimum regulations were met.

This exemption allows us to ship specimens and samples without declaring
them as hazardous materials because they are small quantities, with a
maximum cap.  It also allows you to ship things quicker, and possibly
cheaper.  If you have more than 1 L of ETOH that you want to ship, then you
would be best off splitting your package into multiple packages that are
under 1L net ETOH.

Andy