[NHCOLL-L:2311] shipping methods for specimens
Bentley, Andrew Charles
abentley at ku.edu
Wed Jun 16 12:35:55 EDT 2004
Jamie
I think you are missing the bigger picture here. There is no way that you can ship specimens overseas using USPS - LEGALLY!! USPS follows IATA regulations which state no hazardous materials may be shipped internationally - IN ANY QUANTITY. The only way to legally ship specimens overseas in using a carrier like Fed-Ex, UPS or DHL and even then they require you to have a hazardous shipment agreement with them. Domestically you can ship specimens USPS using the small quantities exemption listed below (I have attached the relevant regulations as they pertain to us as outlined by our EHS Department here on campus). A large part of the problem is that everyone has a different interpretation of the regulations and the regulations that we fall under do not specifically address natural history materials (the regulations having been drawn up to cover bulk alcohol and the perfume industry). We thus fall through the cracks of the regulations.
A special committee has been set up by SPNHC to deal with this issue, of which I am a committee member. We are hoping that, at the very least, the committee will be able to get a consistent ruling on these regulations and at the most, will be able to get USPS and IATA to agree to provide natural history museums with independent regulations that apply to us and us only. The committee will be announcing any progress in this regard as soon as we have any.
Section 334 of the USPS Publication 52 states:
**************************************************************************************
23 July 1999
334 Small Quantity
334.1 Definition
A small quantity is the maximum amount of a specific hazardous material that is not subject to any DOT requirements (i.e., packaging, marking,
labeling) other than those in 49 CFR 173.4. Not every hazardous material is eligible to be shipped as a small quantity. Additionally, for postal purposes Class 7 materials are not permitted to be sent as a small quantity.
The DOT small quantity provision, like the DOT ORM-D category, is unique to the United States. Its use is prohibited with international shipments of hazardous materials and cannot be used in international mail.
334.2 Mailability
Hazardous materials in Class 3, Division 4.1, Division 4.2 (Packing Groups II and III only), Division 4.3 (Packing Groups II and III only), Division 5.1, Division 5.2, Division 6.1 (Packing Groups II and III only), Class 8, and Class
9 are eligible to be sent in the domestic mail under the small quantity provision only when each primary receptacle is limited to the following quantity, as applicable:
a. 30 ml (1 oz) or less for liquids other than Division 6.1 (Packaging
Group I) materials.
b. 30 g (1 oz) or less for solids other than Division 6.1 (Packaging
Group I) materials.
c. 1 g (0.04 oz) or less for Division 6.1 (Packing Group I) materials.
334.3 Packaging and Marking
Hazardous materials eligible to be shipped under the small quantity provision permitted in 49 CFR and 334.2 must be prepared following Packaging Instruction 10A in Appendix C. Each mailpiece that qualifies to be sent under the small quantity provision must be clearly marked on the address side with the following words: "This package conforms to 49 CFR 173.4."
************************************************************************************
Therefore, 30 mL or less of ethanol (Class 3; at any concentration) in an inner container is acceptable for Domestic mail as long as you follow what USPS states in 334 and follow USPS Packaging Instruction 10A, which states:
************************************************************************************
Appendix C USPS Packaging Instructions
USPS Packaging Instruction 10A
Small Quantity Provision
Some types of hazardous materials, as permitted in 334 and 49 CFR 173.4, may be prepared for mailing using the "small quantity" provision. The small quantity provision, like the ORM-D materials category, is unique within the United States, and its use is prohibited in international mail.
Proper Shipping Name and ID Number
- Not applicable.
Prototype Testing Requirement
- The complete mailing package must be capable of withstanding the test criteria in 49 CFR 173.4(a)(6).
Mailability
- International Mail: Prohibited.
- Domestic Mail: Permitted via air transportation (i.e., Express Mail, Priority Mail, and First-Class Mail rates) or surface transportation (i.e., Standard Mail rates).
Required Packaging
Inner Receptacle
- Each inner receptacle cannot be liquid-full at 131° F (55° C).
- Each inner receptacle must be constructed of plastic with a minimum thickness of no less than 0.2 mm (0.008 inch) or must be made of earthenware, glass, or metal.
- Each inner receptacle must be securely sealed with wire, tape, or other positive means.
Absorbent and Cushioning Material
- Sufficient absorbent material that will not react chemically with the hazardous material must fully surround each inner receptacle and be capable of absorbing the entire liquid contents of the inner
receptacle(s) in case of leakage.
- Each primary receptacle must be surrounded by sufficient cushioning material to absorb shock and prevent breakage.
- The absorbent and cushioning materials used must not violate 49 CFR 173.21.
Secondary Packaging
- Each inner receptacle and the absorbent cushioning material must be placed within a securely sealed secondary packaging.
Outer Packaging
- The secondary packaging must be securely packed in a strong outer packaging.
- The total weight of each mailpiece must not exceed 64 pounds (29 kg).
Marking
- The address side of each mailpiece sent under the small quantity provision must be clearly marked with "This package conforms to
49 CFR 173.4."
- A complete return address and delivery address must be used.
*****************************************************************************
49 CFR 173.4 states:
*****************************************************************************
§ 173.4 Small quantity exceptions.
(a) Small quantities of Class 3, Division 4.1, Division 4.2 (PG II and III), Division 4.3 (PG II and III), Division 5.1, Division 5.2, Division 6.1, Class 7, Class 8, and Class 9 materials that also meet the definition of one or more of these hazard classes, are not subject to any other requirements of this subchapter when-
(1) The maximum quantity of material per inner receptacle or article is limited to-
(i) Thirty (30) mL (1 ounce) for authorized liquids, other than Division 6.1, Packing Group I, Hazard Zone A or B materials;
(ii) Thirty (30) g (1 ounce) for authorized solid materials;
(iii) One (1) g (0.04 ounce) for authorized materials meeting the definition of a Division 6.1, Packing Group I, Hazard Zone A or B material; and
(iv) An activity level not exceeding that specified in §§173.421, 173.424, 173.425 or 173.426, as appropriate, for a package containing a Class 7 (radioactive) material.
(2) With the exception of temperature sensing devices, each inner receptacle:
(i) Is not liquid-full at 55 °C (131 °F), and
(ii) Is constructed of plastic having a minimum thickness of no less than 0.2 mm (0.008 inch), or earthenware, glass, or metal;
(3) Each inner receptacle with a removable closure has its closure held securely in place with wire, tape, or other positive means;
(4) Unless equivalent cushioning and absorbent material surrounds the inside packaging, each inner receptacle is securely packed in an inside packaging with cushioning and absorbent material that:
(i) Will not react chemically with the material, and
(ii) Is capable of absorbing the entire contents (if a liquid) of the receptacle;
(5) The inside packaging is securely packed in a strong outside packaging;
(6) The completed package, as demonstrated by prototype testing, is capable of sustaining-
(i) Each of the following free drops made from a height of 1.8 m (5.9 feet) directly onto a solid unyielding surface without breakage or leakage from any inner receptacle and without a substantial reduction in the effectiveness of the package:
(A) One drop flat on bottom;
(B) One drop flat on top;
(C) One drop flat on the long side;
(D) One drop flat on the short side; and
(E) One drop on a corner at the junction of three intersecting edges; and
(ii) A compressive load as specified in §178.606(c) of this subchapter.
Note to Paragraph (a)(6):
Each of the tests in paragraph (a)(6) of this section may be performed on a different but identical package; i.e., all tests need not be performed on the same package.
(7) Placement of the material in the package or packing different materials in the package does not result in a violation of §173.21;
(8) The gross mass of the completed package does not exceed 29 kg (64 pounds);
(9) The package is not opened or otherwise altered until it is no longer in commerce; and
(10) The shipper certifies conformance with this section by marking the outside of the package with the statement "This package conforms to 49 CFR 173.4" or, alternatively, until October 1, 2001, with the statement "This package conforms to the conditions and limitations specified in 49 CFR 173.4."
(b) A package containing a Class 7 (radioactive) material also must conform to the requirements of §173.421(a)(1) through (a)(5) or §173.424(a) through (g), as appropriate.
(c) Packages which contain a Class 2, Division 4.2 (PG I), or Division 4.3 (PG I) material conforming to paragraphs (a)(1) through (a)(10) of this section may be offered for transportation or transported if specifically approved by the Associate Administrator.
[Amdt. 173-224, 55 FR 52608, Dec. 21, 1990, as amended at 56 FR 66265, Dec. 20, 1991; Amdt. 173-234, 58 FR 51531, Oct. 1, 1993; Amdt. 173-244, 60 FR 50307, Sept. 28, 1995; Amdt. 173-253, 61 FR 27173, May 30, 1996; 65 FR 50460, Aug. 18, 2000; 65 FR 58628, Sept. 29, 2000; 66 FR 33426, June 21, 2001; 66 FR 45183, 45379, 45381, Aug. 28, 2001; 67 FR 61013, Sept. 27, 2002]
*******************************************************************************************************
A : A : A :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
V V V
Andy Bentley
Ichthyology Collection Manager
University of Kansas
Natural History Museum & Biodiversity Research Center
Dyche Hall
1345 Jayhawk Boulevard
Lawrence, KS, 66045-7561
USA
Tel: (785) 864-3863
Fax: (785) 864-5335
Email: ABentley at ku.edu :
: :
A : A : A :
}<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
V V V
-------------- next part --------------
An HTML attachment was scrubbed...
URL: http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20040616/6d84ef43/attachment.html
-------------- next part --------------
A non-text attachment was scrubbed...
Name: not available
Type: image/jpeg
Size: 4911 bytes
Desc: image002.jpg
Url : http://mailman.yale.edu/mailman/private/nhcoll-l/attachments/20040616/6d84ef43/attachment.jpe
More information about the Nhcoll-l
mailing list