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;
(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 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 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.