Environmental Health & Safety Manual (EHS)

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Effective: 3/1/2008

Revised: 9/15/2009

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EHS 406: Shipping and Receiving Hazardous Materials

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Purpose

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To ensure that regulations are followed when hazardous materials or dangerous goods are received, shipped, or offered for shipment.

To ensure that ASU is in compliance with US Department of Transportation (DOT) and International Air Transport Association (IATA) regulations.

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Sources

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49 Code of Federal Regulations §§ 172.1–172.804
49 Code of Federal Regulations §§ 173.115–173.140
International Air Transport Association (IATA) 5.0

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Applicability

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Each person who receives, ships, or offers for shipment any hazardous materials or dangerous goods. Offering hazardous materials/dangerous goods for shipment includes outbound and inbound shipments both to and from ASU.

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Background

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The US Department of Transportation (US DOT) mandates specific certified training requirements for persons who receive, ship, or offer for shipment hazardous materials/dangerous goods (HM/DG). Receiving HM/DG requires function-specific training relating to the extent of the person’s involvement. Shipping or offering for shipment—including packaging for shipment and preparation of shipping papers—requires certified training. All training must be documented and all training must be current per regulation.

The US Department of Transportation describes a “hazardous material” as a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce and is designated as hazardous under § 5103 of the federal Hazardous Materials Transportation law. Hazardous materials include: hazardous substances, hazardous waste, marine pollutants, elevated temperature materials, materials designated in the Hazardous Materials Table (49 CFR 172.101), and materials that meet the defining criteria for hazard classes and divisions (49 CFR Part 173).

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Policy

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No person may receive a HM/DG without function-specific training. Training must be documented and included in the employee’s Department of Environmental Health & Safety (EH&S) training record.

Absolutely no materials labeled class 1-explosive, or class 7-radioactive may be received. Refuse any shipment and call EH&S at 5-1823 immediately.

No person may ship or offer for shipment HM/DG unless that person has received certified 16-hour US DOT training for hazardous materials. Additionally, shipments or offers to ship HM/DG by air also require certified International Air Transport Association (IATA) regulations training. All training must be current per regulation, documented, and included in the employee’s EH&S training record.

The shipping function may be completed by a properly trained and certified third-party freight forwarder if one is available.

Shipping or offering for shipment shall include any outbound or inbound shipment to or from ASU being made on behalf of or for ASU. This includes, but is not limited to, shipments of HM/DG from off-campus locations or persons to any campus location or person, or to any permanent or temporary ASU-affiliated off-campus location or person.


Responsibilities

Colleges, Schools, and Other University Departments

It is the responsibility of each college, school, and administrative department to conduct its operations in accordance with all applicable laws and regulations, and to implement this policy as follows, including but not limited to:

  1. informing employees about workplace shipping and receiving procedures
  2. providing required training
  3. investigating incidents and employee complaints
  4. enforcing policies

    and

  5. appropriately documenting shipping and receiving activities.

Environmental Health & Safety (EH&S)

  1. EH&S provides the following training: Laboratory Safety Training; Laboratory Safety Refresher; and Receiving HM/DG for Non-Laboratory Personnel.
  2. The above training serves as function-specific training and meets the requirements to receive HM/DG shipments except for class 1 and class 7 materials. EH&S training schedules are available online or by calling 480/965-1823.

  3. EH&S does not currently provide certified DOT or IATA training. This training is currently available through ASU Polytechnic, Office of Environmental Technology (fee required). The ASUP training schedule is available online or by calling 480/727-1825.
  4. The required certified training is also available through several private sources (fee required). EH&S will assist you in locating a training provider. For assistance please call 480/965-1823.

  5. EH&S will maintain training records and a list of certified shippers, and provide shipping guidance as needed.

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Cross-Reference

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For more information, see EHS 005, “Management Policy.”


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