EHS 406: Shipping and Receiving Hazardous Materials

To ensure that proper procedures 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.

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

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.

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 (49 CFR 172.101). 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 173.115–173.140).

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

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.

Training must be completed prior to receiving any HM/DG. The type of training needed depends on job function:

1. For laboratory workers:

All laboratory personnel are required to attend Laboratory Safety Training (initially) and thereafter Laboratory Safety Training Refresher (annually). Laboratory workers who attend either of these trainings after August 2007 will be considered trained to receive HM/DG except for class 1–Explosive, or class 7–Radioactive; these items may not be received. Contact EH&S for class 1 or class 7 materials. All training must be current per regulation, documented, and included in the employee’s EH&S training record prior to receiving any HM/DG.

2. For non-laboratory workers and office personnel:

All non-laboratory personnel who may receive HM/DG must attend Receiving HM/DG for Non-Laboratory Personnel. This training is required to receive all HM/DG except for class 1–Explosive, or class 7–Radioactive; these items may not be received. Contact EH&S for class 1 or class 7 materials. All training must be current per regulation, documented, and included in the employee’s EH&S training record prior to receiving any HM/DG.

All persons:

Prior to shipping or offering for shipment, packaging for shipment or preparing shipping papers for a HM/DG, you must have and be able to document completion of 16-hour US DOT training for hazardous materials. Additionally, if you intend to ship or offer to ship by air or use a carrier who may ship by air, you must be able to document completion of IATA regulations training. All training must be certified and current per regulation, documented, and included in the employee’s EH&S training record prior to shipping or offering to ship any HM/DG.

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.

The above training serves as function-specific training and meets the requirements to receive HM/DG shipments. EH&S training schedules are available online or by calling 480/965-1823.

2. 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.

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.

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

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. Implementing this policy includes but is 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 and processes.

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