Brown Bag Luncheon Series:  Everything you need to know about shipping and exporting

research materials!

Kevin Charbonneau Deborah FerryManager Safety Advisor Program & Assistant Biosafety Officer &Assistant Radiation Safety Officer Safety Advisor kevin.charbonneau@yale.edu deborah.ferry@yale.edu(203)737-2139 (203)737-2125

EHS Shipping and Exporting Research Materialshttp://www.yale.edu/ehs/hazmatship.htm

Did you answer YES to any of the Questions?

• Do you work in a laboratory based research department? 

• Have you ever shipped research materials?

• Have you ever asked someone else to ship research materials for you? 

• Has anyone ever asked you to prepare shipping documents for packages containing research materials?

• Have you ever shipped a package and have not been fully aware of the contents?

• Have you ever used Accuship to schedule a courier pick-up of a package containing dry ice and/or research materials?

Goals for this Session

Everyone leaves with: a General Awareness of Shipping/Export

requirements an understanding of the new Research

Material Shipping Request process

Definitions

Research Materials are those materials that are used in a laboratory setting which include biological, chemical, and radioactive materials.

Hazardous Materials are defined by shipping and export regulations to include some biological, chemical and radioactive materials.

Note: While not all research materials are considered hazardous by end users there may be training, packaging and licensing requirements mandated by shipping/export regulations.

Shipping & Export Regulations

The following agencies regulate the shipment, transport and export of research materials:

– Department of Transportation– International Air Transport Association (IATA)– Department of Commerce (DOC)– Environmental Protection Agency

• Toxic Substances Control Act (TSCA)

Purpose of Shipping Regulations

To ensure safe shipment of hazardous materials through:• Training people involved in any aspect of shipping• Classifying hazardous materials properly• Packaging hazardous materials to prevent release

during transport• Identifying hazardous materials on the package and

shipping papers

Note: Only TRAINED personnel may be involved in hazardous material shipping or transport. Training information is available on the EHS Website.

Who must be trained?

Employees that perform any of the following with hazardous materials must be trained on a regular basis:

• Packaging• Preparing Shipping Paperwork• Handling• Transporting• Receiving

Potential Impact on many Faculty and Staff

Accuship Data (Jan. – June 2009)

FedEx Data - First Half 2009Month/Shipment Type Jan Feb Mar Apr May June Total Projected 2009

ECONOMY-2DAY-4:30PM 312 376 205 183 224 192 1492 2984

EXPRESS-SAVER-4:30PM 114 76 91 114 55 124 574 1148

FIRST-OVERNIGHT-8:00AM 9 17 5 13 9 15 68 136

INTERNATIONAL-ECONOMY 53 115 121 101 130 169 689 1378

INTERNATIONAL-PRIORITY 276 248 287 261 288 282 1642 3284

PRIORITY-10:30AM 1084 1674 1775 1678 1390 1296 8897 17794

STANDARD-OVERNIGHT-3:00PM 1165 1003 1206 1021 1000 1089 6484 12968

FEDERAL EXPRESS (FDE) Total 3013 3509 3690 3371 3096 3167 19846 39692

EHS Shipping Metrics

EHS Shipping & Export Services

0

100

200

300

400

500

600

Total Shipments Domestic Shipments InternationalShipments

MTA Review s

2007

2008

2009 (1st Quarter)

2009 Projected

EHS is here to HELP!

New Research Material Shipping Website

New Online Research Material Shipping Request FormsNon-regulated Biological Materials

If the biological material you are shipping:

• does not contain human or animal pathogen(s),

• is not a material of human or animal origin,

• is not a genetically modified microorganism infectious to humans or animals, including defective pathogen vectors, or a genetically modified organism containing a human or animal pathogen,

• is not a genetic element or plasmid associated with

the pathogenicity or toxicity of organisms,

• is not packaged with dry ice or liquid nitrogen,

Complete a Research Materials Shipment Request for Non-Regulated Biological Materials.

Instant approval via “Thank You” page

New Online Research Material Shipping Request FormsNewly Synthesized or Imported Chemicals

If the chemical you are shipping is:

• newly synthesized, or previously imported, by staff in your laboratory, to be used solely for scientific experimentation, analysis, or research purposes within the United States, the chemical may not be regulated when shipped.

• not packaged with dry ice or liquid nitrogen,

Complete a Research Materials Shipment Request for Synthesized/Imported Chemicals.

Instant approval via “Thank You” page

New Online Research Material Shipping Request FormsFor all other Research Materials

Complete a standard Research Materials Shipping

Request Form

EHS must approve prior to shipping material.

Enhancements to Training Modules

General Awareness Training Will be required via TMS within the next few weeks

Revamped Biological Shipping Training: Category A (Includes Category B, Exempt Human and Animal

Specimens, Dry Ice and Security Plan Training) Category B (Includes Exempt Human and Animal Specimen, Dry

Ice) Dry Ice Training

All attendees today get Credit for the General Awareness Training

Fully Trained EHS Shipping Team

Export LicensesExport licenses are permission from the federal government to ship

material to another country.

License requirements depend on:• What is being shipped • Where the item is being shipped to• Who the item is being shipped to• How the item will be used

Visual Compliance

Toxic Substances Control Act

Note: EHS will assist you in evaluating materials being Imported or Exported for compliance with TSCA. More information can be found at the following website: TSCA

The Toxic Substances Control Act (TSCA) is administered by the EPA. It is intended to

ensure that human health and environmental effects of research materials are identified

and addressed prior to transport.

Toxic Substances Control Act

Note: EHS will assist you in evaluating materials being Imported or Exported for compliance with TSCA. More information can be found at the following website: TSCA

TSCA requirements for the following:

Chemical Exports, Shipping Newly Synthesized Chemicals or Shipping Previously Imported Chemicals

1. Complete a "Research Material Shipment Request" 2. Complete the "TSCA Chemical Substance Transfer Form" and

"Preliminary Chemical Health and Safety Information Sheet". Send Copies with shipment.

3. Maintain copies of the forms and any associated shipping paperwork in your laboratory's TSCA folder or binder for 3 years from the shipment date.

4. Forward all 3 forms to EHS for review via email to ehshazmat@yale.edu and do not ship the material until you receive a response from EHS.

Toxic Substances Control Act

Note: EHS will assist you in evaluating materials being Imported or Exported for compliance with TSCA. More information can be found at the following website: TSCA

TSCA requirements for the following:

1. Complete a "TSCA Import Certification Form" 2. The Certification form must accompany the package as the Custom’s Officers will

be looking for it. 3. Maintain copies of this form and any associated shipping paperwork in your

laboratory's TSCA folder or binder for 3 years from the importation date.

Importation of Chemicals into the US for “Research Purposes”

Impact on Research

Failure to follow shipping/export regulations may result in the following:• Package delays during transport

• Mishandling by the courier

• Potential for an inadvertent release of the contents

• Criminal and civil penalties (Note: As of October 2007, penalties have increased up to

20 years imprisonment and $1,000,000 in fines)

Complying with shipping regulations protects the material being shipped, those individuals handling the package, and the potential for negative impacts on the environment.

Additional Shipping Restrictions

• Accuship may not be used to ship hazardous materials; this includes shipments where the only hazard is dry ice.

• Research materials may not be hand carried onto an aircraft in any manner.

• The Yale shuttle, including the Yale-VA route, may not be used to transport research materials.

• Due to Veterans Administration (VA) regulations, research materials may not be transported to or from the VA Medical Center, West Haven in a personal vehicle.

• Live infected research animals are forbidden in aircraft. If you have questions regarding shipping requirements for live animals, please contact YARC at the following website: http://info.med.yale.edu/yarc/index.htm.

What do shippers need to do?

Complete an online “Research Material Shipment Request” form and submit it to EHS.

Note: If you have any questions, please contact EHS at 785-3550 or ehshazmat@yale.edu. For more information, visit the EHS website: Shipping Research Materials

EHS Support

• Once the shipment request is received, EHS will perform the following verifications:

– Shipper has received and successfully completed the appropriate training;

– Ensure the shipper has properly classified the shipment and is using the proper packaging;

– For International shipments, export requirements are verified.

• Apply for export licenses on behalf of the PI• Provide shipping/export training for biological materials• Ship highly regulated materials like Radioactive Materials and

certain Chemicals• Maintain required documentation• Assist during regulatory audits

Important

Completing this training does not authorize you to ship hazardous materials. Additional training is required. Please contact EHS at 785-3550 for more information or refer to the EHS website:

Shipping Research Materials.

Additional Information

Yale EHSEnvironmental Health and Safety:

http://www.yale.edu/oehs/hazmatship.htm

Yale University ResourcesOffice of the Vice President and General Counsel:

http://ogc.yale.edu/legal_reference/export_controls.html

Office of Grant and Contract Administration:http://www.yale.edu/grants/policies/exportcontrols.html

Transport and Relocation Services:http://www.yale.edu/transportation/Import.htm

Animal Resource Center:http://info.med.yale.edu/yarc/qa/index.htm

THANK YOU!