Not every question I receive comes from an industrial facility embedded on the outskirts of some major city or from a busy transportation hub in the nation’s heartland. Some, like this one on March 14th, 2015, come from exotic locations I can only hope to visit some day.
You can tell I was impressed (3.14.15):
Here’s what I sent to him later that day. (Yeah, I work Saturdays.):
Note from Dan: The domestic transportation of a hazardous material is always subject to the Hazardous Material Regulations of the the PHMSA/USDOT. A domestic shipper of HazMat by air will likely also have to comply with the Dangerous Goods Regulations of IATA; this depends on your air carrier since most - but not all - require compliance with the IATA DGR. The international transportation of a HazMat (called dangerous goods) by air must comply with the IATA DGR. The direct transportation of a HazMat from San Diego, CA to Hawaii is not international transportation and therefore is only required to comply with the HMR unless the carrier requires compliance with the IATA DGR as well. Got it?
A180 Non-infectious specimens, such as specimens of mammals, birds, amphibians, reptiles, fish, insects and other invertebrates containing small quantities of UN 1170, UN 1198, UN 1987, or UN 1219 are not subject to these Regulations provided the following packing and marking requirements are met:
(a) specimens are:
1. wrapped in paper towel and/or cheesecloth moistened with alcohol or an alcohol solution and then placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30 mL; or
2. placed in vials or other rigid containers with no more than 30 mL of alcohol or an alcohol solution;
(b) the prepared specimens are then placed in a plastic bag that is then heat–sealed;
(c) the bagged specimens are then placed inside a another plastic bag with absorbent material then heat sealed;
(d) the finished bag is then placed in a strong outer packaging with suitable cushioning material;
(e) the total quantity of flammable liquid per outer packaging must not exceed 1 L; and
(f) the completed package is marked “scientific research specimens, not restricted Special Provision A180 applies”.
The words “not restricted” and the special provision number A180 must be included in the description of the substance on the Air Waybill as required by 8.2.6, when an Air Waybill is issued.
He fired back on March 16th:
from 250ml of ethanol per bottle to 30ml of ethanol per vial?How would I have to pack this then? Can I place 30 vials with 30ml
ethanol in a bag with absorbent material, then place the bag into a
box, and then place that box into another box that is aligned with
absorbent material and a plastic bag?
Thank you for your help.
A quick reply the same day:
Some more information was needed (3.17.15):
My reply that same day:
- Non-bulk packaging (i.e. <119 gallons).
- Combination packaging (i.e. inner packaging and outer packaging).
- “strong outer packaging”
- Limits on volume of inner packaging based on packing group of HazMat.
- Shipment by air has additional general packing requirements.
- Shipment by air requires labels and markings in addition to Limited Quantity marking.
However, you will likely also have to comply with requirements of IATA Dangerous Goods Regulations (depending on the requirements of your air carrier). I have access to those regulations but cannot print and send them as I can the USDOT. IATA regulations are similar to USDOT but may have more restrictions and may also have Carrier variations not included in USDOT.
And that’s where my involvement ended. My inquisitor contacted Ron who assisted him through the final steps of packaging and shipping the hazardous material/dangerous good.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
International and Domestic
Daniels Training Services
Please don’t hesitate to contact me with your questions about the transportation of dangerous goods/hazardous materials.