[NHCOLL-L:3111] RE: FW: Shipping of dangerous goods
Gregory Watkins-Colwell
gregory.watkins-colwell at yale.edu
Wed Jun 7 08:01:30 EDT 2006
Jamie,
During our training the instructor made it clear
that the use of UN3334 for our concentrations of
formaldehyde is entirely up to the carrier. Has
anybody contacted FedEx and/or UPS to see what they want done?
Greg
PS remember, consumer commodities are exempt from
the majority of this stuff anyway. that is, if
Microsoft had "MS FOrmalin" for sale, it would be
ship-able without most of this. That's why you
can go into Home Depot and by a jug of something
and drive it home, take it on your boat, do
whatever you want with it (except fly), but if
you order the same stuff from Sigma you'd need
some documentation and probably wouldn't be able
to drive it in your personal vehicle. That said,
did anybody notice the new limitations on Lithium
Ion batteries? no more than 2 per person in air
travel now. How many passengers with PDAs, or
digital cameras, are going to be violating this little law? fun fun fun
At 03:12 PM 6/6/2006, you wrote:
>Thanks Andy,
>
>I want to be sure I understand this. The US DOT
>ruled that formalin (3.7% formaldehyde) is not
>regulated as a Class 9 substance because it
>contains less than 10% formaldehyde? Seems like
>that's a rather arbitrary cutoff, as anyone who
>works with formalin knows how unpleasant it is -
>even at the concentrations we use, it seems hard
>to believe it wouldn't be classified as UN 3334
>("Aviation regulated liquid, n.o.s."), a Class 9 substance:
>
>"Any material which has narcotic, noxious or
>other properties such that in the event of
>spillage or leakage on an aircraft, extreme
>annoyance or discomfort could be caused to crew
>members so as to prevent the correct performance of assigned duties."
>
>Certainly this is open to interpretation but as
>far as I know, the burden of proof would be on
>the shipper if an IATA or DOT inspector declared
>a package containing formalin to be dangerous
>goods. Formalin, in the confined space of an
>airplane, would clearly cause "discomfort" in
>most people. That's why we work with it in a
>hood or in the presence of other adequate
>ventilation. Whether it would cause people to
>falter in their duties is questionable, but we
>have to get all the gray areas removed from this
>issue. As Andy noted, we desperately need
>consensus and consistency on these
>matters. Leaving things open to interpretation invites trouble.
>
>Andy's question about why wintergreen is
>unregulated ("...due to some lobbying by the
>undertakers who use this in embalming...") is
>interesting. We as a community have discussed
>this dangerous goods problem for at least the
>last three years, and we still have no permanent
>solution. I don't understand why we don't use
>our government representatives to approach the
>regulatory agencies, airlines, carriers, etc.
>and get the rules changed. I know we are moving
>in that direction now, but why the
>delay? Corporations do this routinely,
>especially in the US. And it seems they don't
>just get exemptions; they get rewritten
>rules. Natural history museums are global in
>distribution and the scope of their work, which
>should actually make lobbying easier. I wonder
>how long a multi-national corporation like
>Microsoft (or Anheuser-Busch for a more accurate
>comparison) would sit idle while some government
>regulations inhibit their business practices.
>
>Andy Bentley has gone far above and beyond the
>call of duty in his pursuit to get these matters
>resolved. When the dangerous goods shipping
>problem is finally resolved, I propose it be
>termed "the Bentley Solution" or some such thing
>to recognize all his hard work. He has truly
>done a fantastic job. But we are probably
>kidding ourselves if we (as a community) think
>we can fix this alone. As distasteful as it may
>be, perhaps the corporate model is the one we
>should follow in this case. We don't need to
>pay off politicians in some dark alley or back
>room, but let's at least get them
>involved. "Big Business" has shown us
>repeatedly that this works (most folks complain
>about some aspect of it every day). Our museums
>and universities are becoming more and more
>corporate every year; why not embrace it for once and get this problem fixed?
>
>Sorry for my naive rant.
>
>Jamie
>
>
>Mr. James B. Ladonski
>Assistant Collections Manager
>Division of Amphibians and Reptiles
>The Field Museum
>1400 S. Lake Shore Drive
>Chicago, IL 60605-2496 USA
>phone: 312-665-7722
>fax: 312-665-7697
>email: jladonski at fieldmuseum.org
>http://www.fieldmuseum.org/research_collections/zoology/divisions_amphibians.htm
>
>
>
>At 6/6/2006 10:35 AM, Bentley, Andrew Charles wrote:
>
>>Hi all
>>
>>
>>
>>OK, apparently, AGAIN, I am incorrect. As what
>>we are using (3.7% formaldehyde) is below the
>>10% outlined as the lower limit for classifying
>>formaldehyde as a Class 9 substance, it is UNREGULATED by DOT and IATA.
>>
>>
>>
>>This again highlights the need to get an
>>authoritative ruling on all of this and is what
>>I will be striving for in the near future a
>>workshop in DC, bringing all interested parties
>>and representatives of DOT, IATA, ICAO, USPS,
>>Fed-Ex, DHL and UPS together to get to the bottom of this.
>>
>>
>>
>>Apologies again
>>
>>
>>
>>Andy
>>
>> 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
>>
>>From: owner-nhcoll-l at lists.yale.edu
>>[mailto:owner-nhcoll-l at lists.yale.edu] On Behalf Of Bentley, Andrew Charles
>>Sent: Tuesday, June 06, 2006 10:10 AM
>>To: NHCOLL-L at lists.yale.edu
>>Cc: Rossillon, Jon
>>Subject: [NHCOLL-L:3106] FW: Shipping of dangerous goods
>>
>>
>>
>>Hi all
>>
>>
>>
>>I have just received an interpretation from my
>>contact at IATA regarding the shipping of what
>>we call 10% formaldehyde (actually a 3.7%
>>formaldeyhde solution). What I get from his
>>interpretation is that UN 1198 is regulated as
>>flammable due to the presence of methanol in
>>the mixture whereas UN 2209 is simply an
>>aqueous solution of formaldehyde and water (NO
>>methanol). I have just checked and what we
>>order is UN 1198 WITH methanol flammable at
>>full concentration and classed as a Class 3,8,
>>Packing Group III substance. Once diluted to
>>3.7%, as we do, this is no longer
>>flammable. However, the flammability risk
>>aside, DOT has issued a ruling that
>>formaldehyde is a noxious substance that may
>>cause a hazard to occupants of an aircraft if
>>opened and thus is classified as a Class 9,
>>Packing Group II substance for AIR
>>transport. The MSDS for 3.7% formaldehyde
>>(obtained from Sigma-Aldrich) states as
>>such. An interesting aside is that a similar
>>MSDS from Sigma Aldrich but containing
>>Wintergreen is unregulated is this due to the
>>odor masking qualities of wintergreen or due to
>>some lobbying by the undertakers who use this
>>in embalming??? What would wintergreen do to
>>our specimens? Is this stuff commercially available?
>>
>>
>>
>>This aside, this means that 3.7% formaldehyde
>>can be transported by air ONLY using
>>small/excepted quantity regulations (30ml
>>internal package: 500ml total) both
>>domestically using DOT 173.4 and
>>internationally using IATA 2.7. Again, you
>>MUST BE TRAINED to use these regulations and
>>must follow all packing and shipping guidelines
>>as outlined by DOT and IATA. I am trying to
>>get a copy of the actual DOT ruling so that I
>>have the actual verbiage that they use. If
>>anyone has a copy of this I would appreciate seeing it.
>>
>>
>>
>>Thanks
>>
>>
>>
>>Andy
>>
>> 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
>>
>>From: BRENNAN Dave [mailto:BRENNAND at iata.org]
>>Sent: Tuesday, June 06, 2006 9:18 AM
>>To: Bentley, Andrew Charles
>>Subject: RE: Shipping of dangerous goods
>>
>>
>>
>>Andy,
>>
>>
>>
>>I believe that the difference between the UN
>>1198 Formaldehyde, solution, flammable and UN
>>2209 Formaldehyde solution will be that the UN
>>1198 will be a solution using ethanol or
>>methanol, which will create the flammability
>>risk. An aqueous solution with 25% or more
>>formaldehyde will just be corrosive. For
>>solutions with between 10% and less than 25%
>>formaldehyde there has been an interpretation
>>issued by US DOT that because of the noxious
>>properties of the substance it should be
>>classified as UN 3334 Aviation regulated liquid, n.o.s.*.
>>
>>
>>
>>I hope that this is of assistance.
>>
>>
>>
>>Regards,
>>
>>David BRENNAN
>>Assistant Director
>>Special Cargo Standards
>>Ph: +1-514-874 0202 Ext 3289
>>Fax: +1-514-874 2660
>>
>>International Air Transport Association
>>800, Place Victoria, PO Box 113
>>Montreal, Quebec, Canada, H4Z 1M1
>>www.iata.org/dangerousgoods
>>
>>
>>
>>
>>
>>From: Bentley, Andrew Charles [mailto:abentley at ku.edu]
>>Sent: Thursday, 1 June 2006 14:47
>>To: BRENNAN Dave
>>Subject: RE: Shipping of dangerous goods
>>
>>Hi Dave
>>
>>
>>
>>I was wondering if I could elicit your
>>assistance with an interpretation of the IATA regulations once more.
>>
>>
>>
>>In a number of cases specimens are preserved in
>>10% formaldehyde - 37% formaldehyde mixed with
>>deionized water and a buffer to make a 10%
>>solution (which is actually a 3.7% solution as
>>it is diluted 9 times but is called 10% for
>>reasons I won't go into) and in various
>>instances these specimens are shipped in the
>>same way that ethanol specimens are.
>>
>>
>>
>>There appears to be some discussion amongst my
>>colleagues as to whether this substance would be regulated by IATA?
>>
>>
>>
>>Some have said that there are two UN numbers
>>for formaldehyde (UN 2209 and UN 1198) and that
>>our solution would more clearly be described by
>>UN 2209 which is a formaldehyde solution with
>>not less than 25% formaldehyde. However UN
>>1198 is classed as Class 3,8 Packing Group III
>>which would be allowed under excepted
>>quantities but is still regulated. There is a
>>also a listing for formalin in the table which
>>refers to the above two mentions. As our
>>concentration is below 25% does this mean that
>>our "10%" formaldehyde is un-regulated? The
>>verbiage appears to be very similar for DOT too.
>>
>>
>>
>>What is a distinction between the two UN numbers? This is unclear to me...
>>
>>
>>
>>Your help would be much appreciated
>>
>>
>>
>> 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
>>
>>From: BRENNAN Dave [mailto:BRENNAND at iata.org]
>>Sent: Wednesday, August 25, 2004 7:38 AM
>>To: Bentley, Andrew Charles
>>Subject: RE: Shipping of dangerous goods
>>
>>
>>
>>Andy,
>>
>>
>>
>>I support your desire to have a clear set of
>>rules that all of your members can work to,
>>without the need for onerous requirements and costs.
>>
>>
>>
>>1. As you correctly point out alcoholic
>>beverages, in retail packagings, containing 70%
>>or less alcohol by volume, in receptacles of 5
>>L or less are not restricted and may be
>>transported in passenger checked or carry-on
>>baggage. I'm not aware of the "domestic"
>>provisions allowing dangerous goods in accepted
>>quantities. There are certainly provisions
>>permitting passengers to carry certain
>>dangerous goods, aerosols, medicines containing
>>alcohol, etc., but these are standard for both
>>domestic and international transport.
>>
>>
>>
>>2. ICAO are the body that determines the
>>'legal' requirements for the international
>>transport of dangerous goods by air. US DOT set
>>the US domestic policy, which tends to mirror
>>that of ICAO. The group responsible within ICAO
>>is the Dangerous Goods Panel (DGP). The DGP
>>comprises members from 14 States (countries) as
>>well as IFALPA (the pilots' association) and
>>IATA. The next meeting of the ICAO DGP is in
>>Abu Dhabi in October 2004. I'd suggest that you
>>approach the US Panel member, Mr. Bob Richard
>>(E-mail: bob.richard at rspa.dot.gov) to raise
>>your proposals. I would suggest that you
>>consider limiting your request to carriage in
>>checked baggage only. My reason for suggesting
>>that is that the increase in screening of
>>carry-on baggage and the security concerns
>>means that are some issues with "unknown
>>liquids". There has also been a concern
>>regarding the carriage of "home brews". I
>>appreciate that you don't fall into this
>>category, however checked baggage would eliminate any problems.
>>
>>
>>
>>3. Transport in the post may be problematic.
>>For domestic US, the USPS can regulate what it
>>likes. However, once you start talking about
>>international air mail the Universal Postal
>>Union (UPU) is the governing body. In this
>>respect the transport of alcohol across
>>international borders becomes an issue. Also
>>the UPU have a very codified set of
>>requirements and from practical experience
>>getting any amendment to those is a very slow process.
>>
>>
>>
>>4. The UN Sub-Committee of Experts on the
>>Transport of Dangerous Goods is responsible for
>>the development of standards to assist the
>>multi-modal transport. I think that your best
>>approach is with the ICAO DGP if what you're
>>looking for is carriage in baggage. The DGP may
>>also be able to propose a way forward to amend
>>the current provision regarding "alcoholic beverages" vs. "ethanol".
>>
>>
>>
>>Regards,
>>
>>
>>
>>Dave
>>
>>David Brennan
>>Assistant Director, Dangerous Goods & Safety
>>IATA
>>800 Place Victoria, PO Box 113
>>Montreal, Quebec, Canada H4Z 1M1
>>Ph: +1-514-874 0202 Ext 3289
>>Fax: +1-514-874 2660
>>E-mail: brennand at iata.org <mailto:brennand at iata.org>
>>
>>Get more with the IATA Dangerous Goods Regulations 2005
>>Order your DGR before September 15 and receive
>>a FREE DGR Quick Reference guide.
>>
>>
>>-----Original Message-----
>>From: Bentley, Andrew Charles [mailto:abentley at ku.edu]
>>Sent: Friday, 20 August 2004 15:38
>>To: BRENNAN Dave
>>Subject: RE: Shipping of dangerous goods
>>Hi Dave
>>
>>I was wondering if I could bother you for some
>>more information regarding shipping of
>>scientific specimens. We have been meeting
>>regarding this and have come up with two
>>categories of shipments that we still need some
>>clarification on - these being international
>>shipments of specimens being sent through the
>>mail and specimens being carried onto planes as hand baggage.
>>
>>What we are wanting to know is the following:
>>
>>
>>On certain occasions we require taking
>>specimens with us on a plane as hand baggage
>>(e.g. returning from a field excursion,
>>repatriating specimens to our collection
>>etc.). Domestic flights have a provision for
>>hazardous substances in "accepted quantities"
>>to be taken on board as hand baggage but there
>>is no such provision for international
>>flights. You are however allowed to take up to
>>5 liters of beverage ethyl alcohol on
>>board. Is there any way that specimens being
>>carried onto a plane could be made to fall
>>under the existing beverage alcohol
>>regulations, thus allowing for up to 5 liters
>>of up to 140 proof ethyl alcohol to be carried
>>onto a plane as hand baggage? The alcohol that
>>we are putting specimens into is beverage grade
>>ethyl alcohol diluted to 70% with distilled
>>water. We are required to obtain a beverage
>>alcohol permit to use and possess the alcohol
>>and so the natural progression of this is that
>>essentially the specimens are preserved in
>>beverage alcohol. In 99.9% of cases we would
>>not come close to the 5 liter limit. We are
>>talking about tablespoons of 70% ethyl alcohol
>>in the majority of these packages. Is there
>>any way that we could make use of existing regulations to make this possible?
>>We would obviously like to attempt to fall
>>within existing regulations, but, if this is
>>not possible, what would it take for us (as an
>>organization of natural history museums) to
>>obtain exemption for these onboard packages as
>>well as international packages being sent by
>>mail? It has become clear to us during our
>>deliberations that regulations are actually
>>promulgated by ICAO and DOT and that maybe we
>>should be approaching these two organizations
>>to obtain such an exemption. Are we correct in
>>this assumption? Do you know whether this is
>>even in the realm of possibility? Who should
>>we approach to, firstly determine if this is
>>feasible and secondly to get such
>>exemption. After all, there are 1000's of
>>museums throughout the world sending in excess
>>of 10 000 such parcels a year, many of which
>>are being sent illegally - either due to
>>ignorance of the regulations or through blatant
>>contravention of the regulations. I would have
>>thought that it would have been in the best
>>interest of such organizations to provide some
>>form of exemption in order to better control
>>and keep track of such shipments. This all
>>goes back to the original problem of there
>>being no specific regulations that these
>>packages fall under and so people are
>>interpreting the regulations (such that they
>>are) in all sorts of different ways. The
>>amounts of alcohol that we are sending in these
>>packages (way less than 30ml per internal
>>package and 500ml total), as well as the method
>>of packaging, means that the hazardous nature
>>of such packages is drastically reduced. We
>>feel fairly confident that if we could get
>>someone to take a look at the materials in
>>question that we could convince them of this fact.
>>The fact that we are now having to ship
>>international shipments of specimens by courier
>>(Fed-Ex, UPS or DHL) we are incurring spiraling
>>costs associated with such shipments. If we
>>could in some way fall within the USPS
>>regulations for shipping, we could get back to
>>our normal mode of operations. As mentioned
>>above, the amounts of alcohol that we are
>>shipping together with standing beverage
>>alcohol regulations, is there no way that we
>>could fall within existing USPS regulations in this regard too?
>>Another organization that we have come across
>>is the UN Transport of Dangerous Goods
>>Sub-Committee. Is this a committee that may be
>>able to assist us in this cause?
>>
>>
>>
>>Any help that you may be able to give in this
>>regard would be greatly appreciated. We are
>>members of an organization called the Society
>>for the Preservation of Natural History
>>Collections (SPNHC) and this organization has
>>put together a committee to look into the
>>issues surrounding transport of natural history
>>specimens. I am on this committee and would
>>like to report any findings or progress to this
>>committee. There are numerous natural history
>>museums throughout the country who are finding
>>it increasingly difficult to operate under
>>these stringent regulations as the loaning of
>>specimens to other institutions, both national
>>and international is a core mission of our operation.
>>
>>
>>
>>Thanks again
>>
>>
>>
>>Andy
>>
>> 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
>>
>>[]
>>
>>
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******************************************************
* Gregory J. Watkins-Colwell
* Vertebrate Zoology
* Yale Peabody Museum of Natural History
* 170 Whitney Avenue, P. O. Box 208118
* New Haven, CT 06520-8118
* Phone: 203/432-3791
* FAX: 203/432-2874
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