Shipping Dangerous Goods - Virginia Commonwealth University

Shipping Dangerous Goods
Preparing/Receiving Shipments Containing
Infectious Substances, Dry Ice, and
Hazardous Chemicals
COURSE CONTENT
I.
Background information
II.
Infectious substances
-Category A: classification, packaging, labeling and documentation
-Category B: classification, packaging, labeling and documentation
III.
Class 9 Shipping
-Dry Ice
-Genetically Modified Organisms
IV.
Shipping Hazardous Chemicals
DANGEROUS GOODS, DEFINITION:
“Articles and substances having hazardous properties which,
if uncontrolled, could adversely affect the safety of passengers,
crew, and/or the aircraft on which they are carried.”
DANGEROUS GOOD-RELATED INCIDENTS
ValuJet Disaster: 1996
Undeclared Dangerous Good:
- Oxygen Generator
DANGEROUS GOOD-RELATED INCIDENTS
2006 - UPS Cargo Plane: Philadelphia, PA
Fire Resulting from improperly packaged dangerous goods
Source: NTSB Accident Publications: http://www.ntsb.gov/publictn/2007/AAR0707.htm
Other reasons for concern:
Civil penalty not less than $250 or more than $25K per violation
THIS MEANS YOU
Willful violation gets you up to $250K per violation and/or 5 yrs
THIS MEANS YOU
Business entity may be fined up to $500K
THIS MEANS YOUR DEPARTMENT
Examples of recent DOT fines
DESCRIPTION
PENALTY
Shipper improperly offered a class 6.1 hazardous material without executing shipping
papers and without marking or labeling the packages, thereby creating an undeclared
shipment. The shipper failed to provide employees training or create and retain records of
training testing.
$11,550
Shipper improperly offered hypochlorite solutions, 8 and sodium hydroxide solution, 8 in
unauthorized non-UN standard 5-gallon open-head plastic pails; failed to register with
PHMSA; offered hypochlorite solution, 8 and sodium hydroxide solution, 8 accompanied
by a shipping paper that failed to include an emergency response telephone number.
$3,044
Shipper improperly offered amines, flammable, corrosive, n.o.s., 3, (8), accompanied by a
shipping paper that (1) failed to provide the secondary hazard class for the material and (2)
failed to include a shipper’s certification.
$3,165
Shipper improperly offered acetone, 3, in unauthorized non-UN standard combination
packages; offered acetone, 3, in combination packages that were not marked with the
proper shipping name of the material or with required package orientation arrows; offered
acetone, 3, in packages that were not labeled, offered acetone, 3, accompanied by a
$12,000
shipping paper that failed to provide (I) the hazard class, (2) identification number, and (3)
packing group for the material, (4) a shipper’s certification, and (5) an emergency response
telephone number, failed to provide general awareness, function-specific, and safety
training.
REGULATORY AUTHORITIES
UN International Civil Aviation Organization (ICAO)
International Air Transport Association (IATA)
Department of Transportation (DOT)
Federal Aviation Administration (FAA)
FedEx & other carriers
VA Commonwealth University
IATA: “Field Reference Guide for Shipping Dangerous Goods by Air”
•
International DG model
•
Defines criteria for DG classification
•
Sets training/certification standards
•
Provides “Identification” section that specifies materials
considered to be DGs, assigns each a unique “UN” number
•
Specifies packaging components and packaging systems to be used
through “IATA Packing Instructions”
•
Specifies labeling, declaration, and emergency procedures
Department of Transportation
Federal Aviation Administration
Dangerous Goods Shipping Requirements (CFR
49.171-180) nearly identical to IATA:
- Packaging & Labeling
- Declaration
- Hazard Assessment
- Training & Documentation
- Emergency Response/Health
& Safety Concerns
TRAINING REQUIREMENTS
E mp loye e s invo lve d in s hip pin g o f DGs
m us t re c e ive trainin g a t le as t e ve ry 2 ye ars
a dd re s s ing :
1 . Ge ne ral e le m e n ts o f IATA/DOT re gs
2 . S pe c ific ta s k train ing (PIs /La b Ma na ge r s)
3 . He alth & s afe ty trainin g
4 . S e c u rity Train ing
DANGEROUS GOODS CLASSIFICATION
Class 1 - Explosives
Class 2 – Gasses (Flammable,
Non-flammable, Poison, and Toxic)
Class 3 – Flammable Liquids
(solvents)
CLASSIFICATION
Class 4 – Flammable Solids
Class 5 – Oxidizers & Organic Peroxides
Class 6 – Poisonous, Toxic & Infectious
Includes Infectious Substances
CLASSIFICATION
Class 7 - Radioactives
Class 8 – Corrosives
(Acids & Bases)
Class 9 - Miscellaneous
Dangerous Goods
Includes Dry Ice &
Genetically
Modified Organisms
INFECTIOUS SUBSTANCE CLASSIFICATION
(Class 6.2)
1. Category A Infectious Substances: Capable of
causing permanent disability, life-threatening or fatal
disease to humans/animals
2. Biological Substances Category B: Potentially
infectious substances not meeting criteria for
inclusion in Category A, shipped for research,
diagnostic, clinical, or patient care purposes
3. Exempt materials: Non-infectious substances or
those which are unlikely to cause disease in humans
or animals
Shipping Category A
Infectious Substances
CATEGORY A INFECTIOUS SUBSTANCES
1. Agents listed on IATA Table 3.6.D. (see handout) are always
assigned to Category A
2. Category A is assigned either of two UN numbers:
- UN 2814: “Infectious substance, affecting humans”
- UN 2900: “Infectious substance, affecting animals”
3. Assignment to Category A based on known medical history/
symptoms of source human or animal, endemic local conditions,
and professional judgment = Hazard Assessment
4. If the PI deems that any agent (even if not listed on Table 3.6.D.)
poses a significant risk to persons of normal health, agent should be
assigned to category A
CATEGORY A INFECTIOUS SUBSTANCES (cont)
5. Emerging Pathogens: If limited epidemiological information
is available, hazard assessment should be conducted based on
available published literature and experience. If hazard
assessment indicates potential for serious/fatal disease to
humans or animals, pathogen must be assigned to Category A.
6. Category A Pathogens: assigned to IATA Packing Instruction
620.
7. Dangerous Goods declaration and 24/7 emergency contact
required!
Table 3.6.D., UN 2814: “Infectious substance, affecting humans”
• Bacillus anthracis (cultures only)
• Hepatitis B virus (cultures only)
• Brucella abortus, melitensis, suis (cultures only)
• Herpes B virus (cultures only)
• Burkholderia mallei, psuedomallei (cultures)
• HIV (cultures only)
• Chlamydia psittaci – avian strains (cultures)
• Avian influenza, highly pathogenic (cultures only)
• Clostridium botulinum (cultures only)
• Japanese encephalitis virus (cultures only)
• Coccidioides immitis (cultures only)
• Junin virus
• Coxiella burnetti (cultures only)
• Kyasanur Forest disease virus
• Crimean-Congo hemorrhagic fever virus
• Lassa virus
• Dengue virus (cultures only)
• Machupo virus
• Eastern equine encephalitis virus (cultures only)
• Marburg virus
• Esherichia coli verotoxigenic (cultures only)
• Monkeypox virus
• Ebola virus
• Mycobacterium tuberculosis (cultures only)
• Flexal virus
• Nipah virus
• Francisella tularensis (cultures only)
• Omsk hemorrhagic fever virus
• Guanarito virus
• Poliovirus (cultures only)
• Hantaan virus
• Rabies virus (cultures only)
• Hantavirus: hemorrhagic fever/renal syndrome
• Rickettsia prowazekii, rickettsia (cultures only)
• Hendra virus
• Rift Valley fever virus (cultures only)
Table 3.6.D., UN 2814: “Infectious substance, affecting humans” (cont)
• Russian spring/summer encephalitis virus (cultures)
• Sabia virus
• Shigella dysenteriae type 1 (cultures only)
• Tick-borne encephalitis virus (cultures only)
• Variola virus
• Venezuelan equine encephalitis virus (cultures only)
• West Nile virus (cultures only)
• Yellow fever virus (cultures only)
• Yersinia pestis (cultures only)
Table 3.6.D., UN 2900 “Infectious substance affecting animals”
• African swine fever virus
• Avian paramyxovirus type 1 (Velogenic Newcastle virus)
• Classical swine fever virus
• Foot and mouth disease
• Lumpy skin disease virus
• Mycoplasma mycoides-contagious bovine pleuropneumonia
• Peste des petits ruminant virus
• Rinderpest virus
• Sheep-pox virus
• Goatpox virus
• Swine vesicular disease virus
• Vesicular stomatitis virus
Category A Infectious: Packaging Instruction 620
1. Triple Packaging System: Rated to withstand 9 m drop test
a. Primary Receptacle: Leak-proof seal, staged in absorbent material
b. Secondary Container: Pressure-resistant (primary or secondary), content list
c. Outer Container: Bears proper markings, ratings (box codes), labels
2. Maximum Allowable Quantities:
a. Passenger aircraft: not to exceed 50 ml or 50 g
b. Cargo Aircraft only: not to exceed 4 L or 4 Kg
3. Dangerous Goods Declaration required: 3 copies attached to outer box
4. Around-the-clock (24/7) emergency contact/responsible person required
(name and number)!
5. Minimum Package Dimensions: no less than 3.9 inches on any side
CategoryAA Infectious Substance
Packing Instruction 620
Packaging Category A Infectious Substances
Shipping name/
UN number
Class 6.2 & Class 9 label
Dry ice weight
weight in Kg.
Destination
“Up” arrows
on 2 opposite
sides of box
(liquids only)
UN box codes
Declaration: 3 copies
Origin + 24/7 emergency
contact information
Optional labels/markings:
Only when quantities exceed allowable limits for “Passenger and
Cargo” aircraft, affix a “Cargo Aircraft Only” Danger Label.
Passenger and Cargo Aircraft < 50 ml or g
Cargo Aircraft Only > 50 ml or g < 4L or Kg
Cargo aircraft only
IF USING COMMERCIAL
SERVICE LIKE
CHEMTREC, IN
ADDITION TO
TELEPHONE NUMBER,
MUST INCLUDE
CURRENT CONTRACT
NUMBER.
620
IF USING A VENDOR
TELEPHONE NUMBER, YOU
MUST HAVE AN AGREEMENT
FROM THE VENDOR THAT
THEY WILL BE RESPONSIBLE
FOR RESPONSE
954
ONLY AN INDIVIDUAL
WITH CURRENT
TRAINING AND
CERTIFICATION MAY
SIGN THE DG
DECLARATION
Virginia Commonwealth University
1000 East Marshall St
Richmond
VA
23298
SHIPPING DOCUMENT RETENTION
Category A Infectious: Shipping
documents must be maintained
at least TWO YEARS following
shipping or receiving shipments of
Category A Infectious Substances:
maintain declaration and waybill.
Category A Example:
You are shipping a rabies virus culture to the CDC in Atlanta. Use the information
below to label the box and fill out the shipper’s declaration (handouts). You may work
in groups and we will go over the example afterwards.
Quantity: 10mL Rabies virus culture (infectious to humans) in a screw top culture tube
(No dry ice required)
Packaging Available: IATA conforming packaging system (all properly tested and
pressurized) to include a 4G Fibreboard outerbox
Consignee:
John Smith
Center for Disease Control
123 Prevention Parkway
Atlanta GA 30062
Attention: John Smith
24/7 Emergency number: Jay Doe 213-555-5555
Air Waybill #: 116548791161
Airport of Destination: Atlanta, GA
Shipping Biological Substances
Category B
BIOLOGICAL SUBSTANCE, CATEGORY B
¾ Agents not listed on Table 3.6.D and where the hazard assessment
indicates an unlikely health risk to humans/ animals of normal health, or
the environment.
¾ UN 3373: “Biological Substance, Category B.”
¾ IATA Packing Instruction 650.
¾ DG Declaration and 24/7 emergency contact not required!
Category B: Packaging Instruction 650
1. Triple Packaging System: Rated to withstand 1.2 m drop test
a. Primary Receptacle: Leak-proof seal, absorbent material added.
b. Secondary Container: Pressure-resistant (primary or secondary), content list
c. Outer Container: Bears proper markings, ratings, labels
2. Maximum Allowable Quantities: All aircraft: not to exceed 4 L or 4 Kg (body
parts/whole organs exempt from quantity restrictions)
3. Dangerous Goods Declaration: not required, Air bill Section 6
(Special Handling) check box indicating: “Dangerous Goods, shipper’s
declaration not required
4. 24/7 Emergency Contact: not required
5. Minimum Package Dimensions: not less than 3.9 inches on any side
Packaging: “Biological Substances, Category B”
⇒ Materials not included on category A
list/not meeting A criteria and unlikely
to cause disease in humans or animals
⇒ Airbill Block 6: “Dangerous Goods,
declaration not required”
⇒ “Biological Substance, Category B”
⇒ UN 3373 Diamond
Shipper
Consignee
Biological Substance Category B
X2
Orientation arrows on
2 opposite sides of box (liquids only)
Max 4L/Kg per package
(body parts/ whole organs are exempt from quantity restrictions)
Virginia Commonwealth University
1000 East Marshall St
Richmond
VA
23298
SHIPPING DOCUMENT RETENTION
Biological Substances, Category B/Dry Ice: Shipping documents
(the waybill and a description of the shipment) must be maintained
for a minimum of TWO YEARS following shipping/receiving
diagnostic specimens.
Category B Example
You are shipping potentially contaminated (with Hepatitis A) human blood
samples to ABC Laboratories for further testing. Use the information below to
label the box and fill out the airway bill (handouts). You may work in groups
and we will go over the example afterwards.
Quantity: 30mL human blood sample
Packaging Available: IATA conforming packaging system (all properly tested
and pressurized) to include a 4G Fibreboard outerbox
Consignee:
Jane Smith
ABC Laboratories
1112 Brookcliff Drive
Dallas, TX 23451
Attention: Jane Smith
Airport of Destination: Dallas
(24/7 Emergency number not required for Category B shipments)
EXEMPT MATERIALS
The following biological materials are not regulated by IATA/DOT:
1. Substances containing nonpathogenic agents or agents not likely to cause
disease in humans/animals or be a health risk to the environment
2. Microorganisms non-pathogenic to humans/animals
3. Neutralized or inactive pathogens no longer a health risk
4. Environmental samples not considered to pose significant infection risk
5. Dried blood spots on absorbent, fecal occult blood tests, blood/blood
components intended for transfusions, organs intended for transplant
6. Patient specimens with minimum likelihood of containing pathogens
Use leak-proof packaging and sufficient inner absorbent, label sturdy outer
box: “Exempt Human Specimen,” or “Exempt Animal Specimen”
Class 9 Shipping:
Dry Ice and
Genetically Modified Organisms
Dry Ice: Packing Instruction 954
1. Packaging System: Shipment must vent CO2 gas to prevent pressure build-up
2. Maximum Allowable Quantities: All aircraft: not to exceed 200 Kg
3. Dangerous Goods Declaration:
a. Not required
b. Air bill Section 6. (Special Handling) check boxes indicating: “Dangerous
Goods, shipper’s declaration not required,”and “Dry Ice” (provide
weight in Kg)
4. 24/7 emergency contact: not required
Improperly packaged shipment containing
dry ice
Improperly packaged shipment containing
dry ice
Improperly packaged shipment containing
dry ice
Packaging Dry Ice Only
Miscellaneous 9 Hazard
Label (for dry ice) Include:
net weight (Kg)/UN # (1845)
In Block 6, FedEx Airbill,
check “DG declaration not
required,” check “dry ice” and
indicate quantity in Kg
Dry Ice
UN 1845
___Kg
Shipper
Consignee
Max 200 Kg per package
Package must be designed
to release CO2 (tape
across styrofoam lids vs
around lid)
Shipping Dry Ice
• If shipping with a Category A Infectious
Substance (or any other dangerous good that
requires a shipper’s declaration) then declare
the dry ice on the shipper’s declaration.
• If shipping with a Biological Substance
Category B a shipper’s declaration is not
required, and therefore the dry ice only needs
to be marked on the airway bill.
Virginia Commonwealth University
1000 East Marshall St
Richmond
VA
23298
Dry Ice Example
You are shipping dry ice. Use the information below to fill out the box
and airway bill (handouts). You may work in groups and we will go
over the example afterwards.
Quantity: 5 kg
Packaging Available (all properly tested): Strong, sturdy non-UN
specification fibreboard box with styrofoam liner
Consignee:
Bill Glass
MBD Inc.
3345 Main Street
Las Vegas, NV 89109
Attention: Bill Glass
Airport of Destination: Las Vegas
Ensure that the shipment is packaged to allow CO2 gas to vent!
CLASS 9. GENETICALLY MODIFIED ORGANISMS
UN 3245: “Genetically Modified Microorganisms” or
“Genetically Modified Organisms”
- Genetically modified organisms not falling under Category A
or B definition
- Capable of altering animals, plants, or microbiological
substances in a way not normally the result of natural reproduction
- Use IATA Packing Instruction 959
Packaging for Success
Category A
Category B
Dry Ice
(UN 2814 or 2900)
(UN 3373)
(UN 1845)
620
650
954
IATA Packaging
Instruction
Packaging
System
Water tight primary
receptacle/ absorbent
Water tight primary
receptacle/ absorbent
Dry ice should be
placed outside of
secondary
packaging. Write
net amount on box.
*Most important:
allow for the
venting of CO2 gas
so your package
doesn’t explode!
Secondary container
Secondary container
Primary or secondary
container pressure
resistant
Primary or secondary
container pressure
resistant
List of contents attached
to secondary container
List of contents attached
to secondary container
Outer container w/
markings/ labels
Outer container w/
markings/ labels
Labels
Class 6.2
UN 3373 label
Class 9 label
Quantity
restrictions
Passenger: 50mL/ 50g
Cargo: 4L/ 4kg
4L or 4kg
200kg
DG declaration
3 copies on box/ 1 for
your files, retain 2 years
Depends on shipment,
Not required; mark on
airway bill, retain 2 years retain 2 years
Shipping Hazardous Chemicals
HAZARDOUS CHEMICALS
Table 4.2 of IATA Guide provides shipping information for
thousands of common chemicals and potentially dangerous
products:
¾ Proper shipping names and UN numbers
¾ Packaging Instructions
¾ Marking and labeling requirements
¾ Quantity restrictions
Substances not listed by name must be assigned generic names/UN
numbers based on hazard assessment and IATA instructions.
CHEMICAL PACKAGING BASICS
¾ Cushioning/Securing: chemicals must be protected from normal
conditions experienced during transport
¾ Ullage: Sufficient space (“ullage’) to allow liquid expansion in container
during transport must be provided
¾ Subsidiary Risk: Chemicals having more than one hazard class,
formalin: primary - Class 3 flammable, subsidiary Class 8 corrosive
¾ Packing Group: Required leak protection based on degree of hazard:
I. High hazard, absorbent sufficient to contain entire contents
II. Medium hazard, absorbent to contain largest inner parcel
III. Low hazard, absorbent not required, leak proof liner used
Hazardous Chemicals
If you will be shipping hazardous
chemicals please consult with OEHS
regarding proper packaging, labeling
and documentation. You will need
information from Table 4.2 in the
IATA field manual.
OEHS: 828-1392
Security Awareness
• Laboratory hazardous materials can be used as terrorist weapons
• Hazardous materials are vulnerable while in transit
• As a general precaution do not discuss transportation routes,
shipments, and destinations with strangers
• Certain mixtures of hazardous materials can result in explosions
• To reduce threat keep dangerous goods secure through the use
of locked doors
Security Awareness
•
Not all criminals/terrorist fit a preconceived image
•
Appropriate background checks can be a significant deterrent to insider
threats
•
When questioned about a shipment ensure the individual is authorized
and has been identified before releasing the shipment information
•
VA Terrorism and Security Awareness Orientation should be
completed by all VCU employees. The link to the website is
http://www.emergencymanagement.vcu.edu/
POINTS TO PONDER
• Couriers/Carriers: bound by federal law to report violations,
have right to set standards more stringent than DOT/IATA
regulations
• Radioactive Materials: All shipments must be approved by
VCU Radiation Safety
• Import/export of dangerous goods may involve additional
shipping requirements
• Infectious Substances: no de minimis quantities
• Shipping documents (declaration and waybill) must be
maintained for 2 years
POINTS TO PONDER
• Operator variations/limitations: FX-18
• Beginning 1/10/2011, FedEx will require all Shipper’s Declarations
originating in the U.S. to be prepared using the following methods:
• FedEx approved vendor software application
• Preapproved shipper proprietary software, or
• FedEx Automated Shipping Solutions that have dangerous
goods error checks
A list of approved DG shipping application vendors can be found at
www.fedex.com/us (keyword: dangerous goods). Shipper declaration
“templates” from FedEx will no longer be accepted.
Dangerous Goods - Shipping Animals?
Live vertebrate and non-vertebrate
animals consigned for shipment may
require special permits from CDC or
USDA
TRAINING RECORDS/REFRESHING
¾ IATA/DOT training is not complete until the supervisor
signs certificate
¾ Supervisors should review work-area and job specific health
and safety training prior to signing DG training certificate
¾ Up-to-date training records must be maintained in PI/
lab manager’s/supervisor’s central files
¾ Training records should be maintained for at least 3 years
¾ IATA/VCU require DG training “refresher” every 2 years
¾ Visit OEHS website (http://www.vcu.edu/oehs/chemical/ )
for training dates
Office of Environmental Safety and Health
Paul Smith 827-0939
Mike Elliott 828-4404
Elizabeth Land 828-1279
OEHS Chemical/Biological Safety Section 828-1392
http://www.vcu.edu/oehs/chemical/
FedEx Dang Goods Hotline: (800) 463-3339 x 81