Number:
3.24
Policy/Operational Procedure Name:
Transporting Hazardous Materials Between Campuses
Sponsor:
Ludwig (Bill) Stuart, Safety Compliance Officer
(Safety Committee)
Effective Date(s): 3/2016
Location:
http://www.durhamtech.edu/policiesprocedures/
hazardousmaterials.htm
Custodian:
Safety Committee and Safety Officer
Next Review Date: Spring 2019
Citation:
DOT 49CFR 171.1(d)(5); 49CFR 173.6
HAZARDOUS MATERIALS REGULATIONS (HMR):
http://www.gpo.gov/fdsys/pkg/CFR-2009-title49-vol2/pdf/CFR­
2009-title49-vol2-part171.pdf
MATERIALS OF TRADE EXCEPTION:
http://www.gpo.gov/fdsys/pkg/CFR-2002-title49-vol2/pdf/CFR­
2002-title49-vol2-sec173-6.pdf
Policy Statement: NA
Procedure:
Transportation of Hazardous Materials 1 between Durham Tech Campus locations shall adhere to the following safety
precautions even though we are exempt from the federal DOT regulations under 171.1(d)(5).
1. The proper Personal Protective Equipment (PPE) will be used when handling unpackaged bottles
2. Hazardous materials stored in non-original bottles will be properly labeled with the chemical name and GHS
hazard symbol or text. Original manufacturer containers will already have this identification.
3. Hazardous materials shipping containers will follow the provisions listed above for Required Packaging under
49CFR 173.6 and list the chemical name, primary hazard class (see appendix below) and approximate quantity
on the outside of shipment packaging. A person with hazardous materials handling experience will package or
inspect the packaging prior to self-transportation for containers not in their original commercial shipment
packaging. Contact the Safety Officer if you need assistance.
4. When handling bloodborne pathogen materials, we will adhere to the OSHA 29 CFR 1910.1030 standard.
Biohazardous materials such as needles and syringes and other “sharps” will be sealed in specially designed
sharps containers (usually used to collect and store these materials) and can be transported without further
packaging unless they contain liquids that could leak. “Sharps” containers with liquids that could leak will be
placed in a secondary sealed container with absorbent material and labeled on the outside with the biohazard
symbol and a description of the contents. Biohazardous materials such as contaminated gloves, disposable lab
coats, plastic pipettes, and other contaminated wastes (no “sharps” allowed) would be placed in a sealed
thick plastic bag labeled on the outside with the biohazard symbol and a description of the contents.
5. Safety Data Sheets [SDS or MSDS] will be available on the Durham Tech web site for all materials shipped.
(http://www.durhamtech.edu/faculty/safety) Paper copies will be carried for highly hazardous materials.
Examples of highly hazardous materials include concentrated acids, bases, highly flammable liquids and highly
toxic substances 2. Examples of materials where a SDS paper copy would not be carried would include low
toxicity wastes and dilute solutions.
6. No Class 1 explosives, pyrophorics or extremely hazardous substances (GHS Category 1 “Fatal if inhaled”) will
be self-transported. No radioactive wastes are to be self-transported. (see Alternative Transportation below)
7. We will voluntarily adhere to the Material Limits under 49CFR 173.6 that have been listed above.
Commercial carrier or Durham Tech shipping department deliveries are not covered by this document.
For the purposes of this document, “highly” is defined as GHS Category 1 or NFPA Diamond rating 4. Consult the (M)SDS for substance Categories
& Ratings.
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1 Transporting Hazardous Materials
Drivers will have the required training (see Required & Recommended Training section below) and are expected to
check-out a college van, fire-extinguisher (if transporting flammables) and spill clean-up kit for transportation
between sites. Kits include basic PPE for minor spills.
Alternative Transportation: As an alternative to self-transportation, contact the Durham Tech receiving department
and request delivery of a vendor shipment to the site where needed.
Required & Recommended Training:
1. Required: SafeColleges Chemical Spills Overview or equivalent completed.
2. Required: SafeColleges Hazard Communication: Right to Understand (GHS) or equivalent completed.
3. Recommended: SafeColleges Personal Protective Equipment (PPE) completed.
4. Recommended: SafeColleges Van Safety completed.
5. Required: read the Durham Tech Emergency Action Plan & Safety Manual: Chemical Hygiene Plan.
Purpose/Definitions:
The US Department of Transportation (DOT) regulates and restricts the transportation of hazardous materials over
public roads and highways. There are times when Durham Tech employees need to self-transport hazardous materials
between Durham Tech sites for various purposes including laboratory resupply.
49CFR 171.1(d)(5): The Primary Provision We Are Following 3
DOT rules list specific functions that are exempt from the federal standard when hazardous materials are being
transported for noncommercial purposes. The exemption applies to “transportation of a hazardous material in a
motor vehicle, aircraft, or vessel operated by a Federal, state or local government employee solely for noncommercial
Federal, state, or local government purposes.” 171.1(d)(5)
49CFR 173.6, Materials of Trade Exception 4
Another provision, 49CFR 173.6, Materials of Trade Exception, allows the transport of limited amounts of hazardous
materials necessary for the conduct of business, as long as that business isn't transportation, without requiring such
things as: a Commercial Driver’s License, formal shipping papers, placards, etc. But there are certain restrictions –
some of which are described below.
Material Limits under 49CFR 173.6:
• For most chemicals: Single containers of no more than 30 kg (66 pounds) or 30 liters (8 gallons).
• For gas cylinders: Gross weight of cylinder no more than 220 pounds.
• Total GROSS weight of all hazardous material is 200 kg (400 lbs)
Things You May Not Transport under 49CFR 173.6: Explosives, Pyrophorics, materials classified as Inhalation Hazards
and Hazardous Wastes.
Required Packaging under 49CFR 173.6:
• Packages must be leak tight for liquids and gases, sift proof for solids, securely closed, secured against movement,
and protected against damage.
• Each material must be packaged in the manufacturer's original packaging, or a packaging of equal or greater
strength and integrity.
• Additional packagings are not required for "receptacles" (e.g., cans and bottles) that are secured against
movement in cages, carts, bins, boxes or compartments. Note, however, biological specimens may require inner
and outer packaging and secondary containment is recommended.
HAZARDOUS MATERIALS REGULATIONS (HMR):
http://www.gpo.gov/fdsys/pkg/CFR-2009-title49-vol2/pdf/CFR-2009-title49-vol2-part171.pdf
4 MATERIALS OF TRADE EXCEPTION:
http://www.gpo.gov/fdsys/pkg/CFR-2002-title49-vol2/pdf/CFR-2002-title49-vol2-sec173-6.pdf
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Other Requirements under 49CFR 173.6: The operator of the motor vehicle must know what he/she is carrying, have
a copy of the pertinent Material Safety Data Sheet, and be prepared to deal with spilled material.
Hazard Classes regarding 49 CFR 173.2
Class 1 Class 2
Class 3
Class 4
Explosives Gases Flammable
Liquids
<=(37.8°C /
100°F)
Class 5
Class 7
Class 8
Class 9
Other
Oxidizing
Toxic
Radioactive Corrosives Miscellaneous
Flammable Substances & (Poisonous) & materials
hazardous
Substances
Organic
Infectious
materials
Peroxides
Substances
Review Action
Operations & Technology Council/ President’s Leadership Council
Campus Community Review
Legal Review
Board of Trustees Review
Class 6
Review
Approved
Date(s)
Date
11/18/2015 E-vote
1/29/2016
3/8/16
1/6/2016 - 1/20/2016
1/6/2016 - 1/20/2016
NA – Procedure only
3 Transporting Hazardous Materials