In order to protect the public, the US Department of Transportation (DOT) regulates the shipment of all hazardous materials by aircraft, railcar, vessel, and highway in the United States via Hazardous Materials Regulations (HMR) 49 CFR Parts 171-180. In conjunction with this, all air shipments (international and domestic) must be prepared according to the International Civil Aviation Organization (ICAO) as published in the International Air Transport Association (IATA) Dangerous Goods Regulations. These regulations require:
- Training for anyone who prepares, offers, or receives regulated materials for shipment
- Responsibilities to be outlined for anyone involved in activities related to the shipment of hazardous materials and dangerous goods
- Nine hazard classes and divisions to be defined
- Proper classification, packaging, labeling and documentation requirements to be defined
- Procedures for security assessment
- Establishment of penalties for non-compliance
The purpose of this program is to provide SMU employees involved with shipping hazardous materials guidance for regulatory compliance. Compliance with DOT regulations is required for all personnel that offer hazardous materials for shipment. Failure to comply can result in civil and/or criminal penalties for the University and the individual.
This program applies to all SMU employees or students that ship packages regulated for transport and to all employees or students that transport hazardous materials.
Authority and Responsibility
Environmental Health and Safety (EHS), in the Office of Risk Management, is responsible for implementing the Hazardous Materials Transportation Program. This includes acting as the technical expert on behalf of the University. EHS will also maintain a certified DOT and IATA shipper to arrange for regulated outgoing shipments. EHS will also advise departments and assist (non-financially) in arranging for personnel to receive Hazardous Material Shipper training as the University or departments deem appropriate.
Departments are responsible for ensuring that their employees and students are complying with elements of this program. They are responsible for ensuring that departmental personnel are arranging shipments through EHS and notifying EHS if personnel are not operating within the parameters of this program. Departments are also responsible for obtaining all shipping and transportation supplies, as necessary.
Employees and students must follow all aspects of this program and ensure that they maintain training requirements as outlined in the program.
Identifying program participants
Departments must identify personnel that shall participate in this program. Currently, all outgoing hazardous materials shipments must be processed through EHS. Departmental personnel that plan to routinely ship hazardous materials must be trained as a Hazardous Materials Shipper through one of our vendors. This would include any personnel that does the following:
- Prepares hazardous materials for shipment (packs, marks, labels shipping containers)
- Offers hazardous materials for shipment (fills out and/or signs shipping papers)
The Hazardous Material Transportation Program also includes anyone that handles hazardous materials packages or transports hazardous materials. These people must also follow all stipulations of this program.
Identifying hazardous materials
Employees and students must be able to identify hazardous materials that are being shipped or received. They can be identified in various ways including:
- Shipping papers
- Safety Data Sheet (SDS) Section 14: Transportation Information
- Package markings and labels
Packages that contain hazardous materials are marked with a diamond-shaped DOT Hazard Class Label or marked ORM-D (regulated consumer commodity).
Gases – Flammable/Non-Flammable/Toxic
Flammable Solids, Pyrophoric/Dangerous When Wet Materials
Oxidizers and Organic Peroxides
Poisons and Infectious Materials
Corrosive Liquids and Solids
Some hazard classes are further broken down into divisions, then to packing groups (PG). There are exceptions to these regulations, including materials of trade (MOT) and materials transported within the University.
Technically speaking, DOT only regulates hazardous materials “shipped in commerce” (i.e., for business purposes or via a shipping carrier). As a University, the majority of our materials are not “shipped in commerce”. This means that there are regulatory exceptions that allow materials to be transported on campus. However, these activities still require safe procedures and training.
- Packages should be opened by the addressee only.
- They shall be inspected for visible signs of damage or leaking. If the package shows any evidence of leaking it should be rejected. If the delivery has already been accepted before noticing leakage, move into a fume hood and follow emergency procedures for a chemical spill.
- Note the presence of any special handling requirements including cold storage or “store under inert gas” prior to opening.
- Hazardous material packages should never be left in an unsecured location. They should not be left in hallways, unattended and unlocked storage areas, etc.
- The package is suspicious, contact SMU Police immediately and do not touch it.
Intra-building movement of hazardous materials
- Anyone transporting hazardous materials must have either Hazard Communication training or Laboratory Safety Training.
- Do not open outer packaging until you have reached your laboratory or shop.
- Use a cart with raised sides for transporting hazardous materials that are at risk of spilling. Safety totes may be used for single bottles.
- Use freight elevators where feasible and do not transport hazardous materials up and down stairs.
Inter-building movement of hazardous materials (non-vehicular)
- SMU employees and students transporting hazardous materials between buildings on campus by foot should use a cart with sidewalls to ensure that the bottles are protected from tipping.
- Avoid high pedestrian and vehicular traffic areas. Also, avoid high traffic times such as during campus events that draw heavy pedestrian traffic or directly after classes let out.
Inter-building movement of hazardous materials (vehicular)
Periodically, it may be necessary for employees or students to transport hazardous materials to other campuses, research sites, or job locations.
NOTE: In this case, the term “hazardous material” does not apply to hazardous waste or radioactive materials. These materials cannot be transported in the following fashion as special regulatory requirements exist. Please contact EHS for more information.
All other hazardous materials may be transported safely following the below practices:
- All personnel transporting hazardous materials must have taken SMU-offered Laboratory Safety Training.
- All containers must be labeled as to their contents.
- Packaging must be the manufacturers original packaging or an equally sturdy package. Previously opened containers must be placed in secondary containment such as a plastic tote. The containment must be compatible with the chemical. Secondary containers must be labeled with the same information as the primary container.
- Avoid transporting compressed gas cylinders without prior approval from EHS.
- Hazardous Materials shall NOT be transported in passenger compartments of vehicles. The trunk or bed shall be used.
- Drivers must have a copy of the SDS with them during transport.
- A log sheet must be maintained by the laboratory that specifies the materials being transported, date of transport, location materials are transported from, location transported to, quantity, number of containers, and hazard class. This sheet must be within reach of the driver during transport. These logs will be subject to periodic EHS review.
- Drivers must have an appropriate spill kit. This kit must consist of appropriate PPE (i.e., gloves, goggles, etc.), absorbent material, small shovel and/or broom and dustpan, and hazardous waste bags. The driver shall only attempt to clean up a spill if it is deemed safe to do so.
- Do not, under any circumstances, leave chemicals stored in a vehicle. Plan routes and travel times appropriately.
- Due to insurance regulations, it is recommended that only University vehicles be used to transport hazardous materials. If an accident occurs in a personal vehicle while transporting hazardous materials, the insurance carrier may not cover the claim. If a personal vehicle is used, the insurance carrier should be consulted prior to transport to determine the level of coverage. University insurance WILL NOT cover individuals using their personal vehicles.
- Any questions about transporting hazardous materials should be directed to EHS at 214-768-2430.
Transporting Biohazardous Materials
Separate instructions guide the transport of biohazardous materials between buildings.
Training and Recordkeeping
All employees and students that handle hazardous materials must take either Hazard Communication training (for non-laboratory personnel) or Laboratory Safety training prior to transporting or working with hazardous materials.
- Hazard Communication training is taken via LawRoom, the SMU contracted training provider. In order to sign up for this training, please contact EHS. A link from Human Resources will be directed to you with information and instructions about the training course.
- For all individuals working in laboratories, Laboratory Safety Training is necessary.
- In both cases, training records will become a part of your permanent file.
- For those individuals that routinely prepare hazardous materials shipment, please contact EHS for specific information regarding training requirements, recordkeeping, etc.
Please contact EHS for information on the Safety and Security Plan.