Shipping Dangerous Goods
Course Content
I. Background information
II. Infectious substances
–
–
–
Category A: classification, packaging,
labeling and documentation
Category B classification, packaging,
labeling and documentation
Exempt human specimens
III. Class 9 shipping
–
Dry Ice
Dangerous Goods, Definition:
Materials or substances having hazardous properties
which, if uncontrolled, are capable of posing a risk to
health, safety, property or the environment.
If you don’t value life, other reasons for concern:
•Civil penalty for individual up to $50,000 for each
violation
•Criminal penalty for individual up to $500,000
and/or imprisonment up to 5 years
•Penalties double if there is serious injury or death
•In addition to the individual, the institution may be
charged
Regulatory Authorities
•UN International Civil Aviation Organization (ICAO)
•International Air Transport Association (IATA)
•Department of Transportation (DOT)/Federal Aviation
Administration (FAA)
•United States Post Office (USPS)
•Individual Air Carriers (FedEx, Alaska Airlines)
Regulations
IATA Dangerous Goods Regulations
Department of Transportation 49
CFR.171-180
Domestic Mail Manual – Publication 52
IATA Dangerous Goods Regulations
Key Points
• Based on UN Model
• In general, are the most restrictive
• DOT will accept
• Post Office will accept
Training Requirements
Anyone who handles, offers for transport, or transports dangerous goods
must be trained to perform the duties required by their employer.
Three areas of training are required;
1. General Awareness/Familiarization Training – Training designed to
provide familiarity with the general requirements of dangerous goods
regulations
2. Function Specific Training – Training that specifically addresses the
functions the employee performs: for example, preparing and offering a
shipment of infectious substances and the use of dry ice in transport
3. Safety Training – Training that instructs the employee of hazards
associated with dangerous goods as well as safe handling and
emergency response procedures – OSHA Blood Borne Pathogen (BBP)
standard (29 CFR 1910.1020) may be used to meet DOT requirements
Employer Certification Requirements
Testing
Demonstration
Oral
Written
Certificate of Training
Employer must have for each employee
Trainee’s name
Date of exam
Description of training materials used to meet training requirements
Name and address of trainer
Test Score
Specific topics for which the employee is trainee
Certificate Validity
2 years for IATA
3 years for DOT
As needed
Responsible Parties
Shippers
Carrier/Operator
Receiver
Shipper’s Responsibilities
• Classify
• Identify
•Select proper packaging
• Packing
• Mark and label
• Document
• Make arrangements
Operator’s Responsibilities
• Must detect errors
• Use acceptance checklist
• Ensure safe loading, storage, and transport
• Inspect for damage or leaks
• Report any problems to the proper
authorities
Receiver’s Responsibilities
• Help obtain import permits, if needed
• Inspect package for damage or leaks
• Verify itemized list of contents
• Report back to shipper
• Report leaking packages to
appropriate authority
Excerpt from Table
List of Dangerous Goods
Classes of Dangerous Goods
Nine classes of dangerous goods
(class indicates type of hazard not degree)
Class 6 Toxic and Infectious Substances
Division 6.2 Infectious Substances
Class 9 Miscellaneous
Dry Ice
Infectious Substances
A material known or reasonably expected to contain a pathogen
Pathogen – a microorganism (including bacteria, viruses, rickettsiae, parasites, fungi) or
other agent, such as a proteinaceous infectious particle (prion), that can cause disease in
humans or animals
Infectious substances come in 2 forms:
Cultures – an infectious substance containing a pathogen that is intentionally propagated
Patient Specimens – human or animal material collected directly form humans or animals
and transported for research, diagnosis, investigational activities, or disease treatment or
prevention. Patient specimen includes excreta, secreta, blood and it components, tissue
and tissue swabs, body parts, and specimens in transport media.
Infectious substances have multiple categories:
Category A – An infectious substance in a form capable of causing
Permanent disability
Life threatening or fatal to otherwise healthy humans or animals
Occurs upon exposure
Category B – An infectious substance that is not in a form generally capable of causing
Permanent disability
Life threatening or fatal to other wise healthy humans or animals
Occurs upon exposure
Exempt Human Specimens – Specimens that do not, or are not likely to contain an
infectious substance, are not subject to the regulations if the specimen is packed in a
manner that prevents leakage
Examples of Category A Substances
Bacillus anthracis (cultures only)
Coccidioides immitis (cultures only)
Lassa virus
Shigella dysenteriae type 1 (cultures only)
Dengue virus (cultures only)
Rabies virus (cultures only)
Hepatitis B virus (cultures only)
Yersinia pestis (cultures only)
Examples of Category B Substances
Staphylococcus aureus
Cryptococcus neoformans
Rabies virus
Hepatitis B virus
Escherichia coli, verotoxigenic,
Streptococcus pneumoniae
Streptococcus pyogenes
Stenotrophomonas maltophilia
Examples of Exempt Human Specimens
Blood or urine specimens for cholesterol
Urine screening for drugs or alcohol
Biopsies to detect cancer
Specimens for antibody detection
Non-Regulated Materials
Unless the following meet the criteria for inclusion in another
class or division, are not subject to the regulations:
• Substances with a low probability of containing an infectious
substance, or where the concentration of the infectious substance is at
a level naturally occurring in the so it cannot case disease when
exposure to it occurs
• Micro-organisms that do not cause disease in humans or animals
• Substances that have been treated so that the pathogens have been
neutralized or deactivated
• Foodstuffs and environmental samples, such as water or a sample of
dust or mold which would not be considered a significant source of
infection
• Dried blood spots or specimens for fecal occult blood detection
placed on absorbent filter paper or other material and blood, blood
components, tissues or organs collected for the purpose of transfusion
or transplantation
Classification Flow Chart
Using the Dangerous Goods List
Name
(Proper Shipping Name)
UN No.
Class or
division
Biological substance,
Category B
3373
6.2
None
Infectious substance,
affecting humans
2814
6.2
Infectious
A81
A140
Infectious substance,
affecting animals, only
2900
6.2
Infectious
A81
A140
Dry ice
1845
9
Miscellaneous
A48
A151
Subsidiary risk
Hazard Labels
Special provisions
UN packing
group
No longer III
Proper Shipping Name
• All dangerous goods must be assigned a proper shipping name
• Proper shipping names must be spelled exactly as they appear on the
list of dangerous goods
UN Numbers
• Each proper shipping name is assigned a UN number
• The UN number can be used to identify the dangerous good
• The UN number is useful when English is not the native language
• The UN number appears alongside the proper shipping name
Hazard Labels
• Hazard labels indicate the class or division of dangerous goods
Special Provisions
• Special provisions give detailed information in the handling of packages
containing the specific dangerous good
Special Provisions
A 48
The completed package does not require testing
A81
Shipments involving body parts, organs or whole bodies infected with a
Category A Infectious substances may exceed the quantity limits for
Passenger or Cargo aircraft
A140
The proper shipping name for Category A Infectious substances must be
supplemented with the technical name (scientific name) on the Shipper’s
Declaration for Dangerous goods. The technical name is not
recommended to be marked on the outside of the package. If the technical
name is not known or if the specimen is proficiency testing, the technical
name “suspected Category A Infectious substance” must be included.
A151
Quantity limits for dry ice do not apply when dry ice is used as a refrigerant
in pallets.
Proper Packaging
Dangerous goods need to be packed in such a way that the specimen is
protected against leakage or spillage during transport
Quantity Limits and Packing Instructions
Passenger Aircraft
Name
(Proper
Shipping Name)
Subsidiary risk
Hazard Labels
Special provisions
Cargo Aircraft
Max net
quantity per
package
Excepted
Quantity
Packing
instruction
Packing
instruction
EO
650
1 L primary 4 L
or 4 kg
650
Max net
quantity per
package
UN No.
Class or division
Biological substance, Category B
3373
6.2
None
Infectious substance, affecting
humans
2814
6.2
Infectious
A81
A140
EO
620
50 ml or
50 g
620
4 L or 4 kg
Infectious substance, affecting
animals, only
2900
6.2
Infectious
A81
A140
EO
620
50 ml or
50 g
620
4 L or 4 kg
Dry ice
1845
9
Miscellaneous
A48
A151
EO
954
954
200 kg
200 kg
1 L primary 4 L
or 4 kg
Proper Packaging Continued
Triple packaging required for:
Category A
Category B
Exempt human specimen
UN specific packaging required for Category A
Manufacturer’s test packaging systems and copies of these reports must
be shown to the inspectors upon request
Comparison Chart of Sample Handling & Packaging
Step
1
2
3
4
Biological Substance, Cat.B (UN3373)
PI650
Place sample in a leakproof primary
receptacle or vial. Vial caps must be
sealed with tape, paraffin, parafilm. The
volume must be 1L or less.
Infectious Substance (UN2814 or
Solid CO2/Dry Ice PI954
UN2900) PI620
If shipped by ground--not regulated, else it Prepare a Dangerous Goods (DG)
must be put in a container that allows the Declaration. Packaging must be UN
release of pressure and prevents rupture. certified. Place sample in a leakproof
primary receptacle or vial. Vial caps must
be sealed with tape , paraffin, parafilm.
Sample vial is then placed in a leakproof
secondary packaging. Examples of
secondary packaging are: plastic canister,
sealed plastic bag, sealed styrofoam,
screw cap can. Total volume of samples
must be 4L or less. Primary or secondary
package must be able to withstand and
internal pressure of 95 kPa and a
temperature range of -400to 550C.
Place absorbent material between
primary receptacle and secondary
packaging. Examples of absorbent material
are: cellulose wadding, cotton balls, paper
towels, commercial absorbent packets.
Cushioning is required if multiple primary
containers are present.
Place the above in an outer packaging.
Examples are corrugated cardboard box,
wood box, rigid plastic cooler, rigid plastic
box. Side of box must not be less than 100
mm. Entire package must be able to pass
drop test of 1.2 meters.
Place the dry ice outside the secondary
packaging.
Sample vial is then placed in a leakproof
secondary packaging. Examples of
secondary packaging are: plastic canister,
sealed plastic bag, sealed styrofoam,
screw cap can. Either primary receptacle or
secondary must be able to withstand an
internal pressure of 95kPa and a
temperature range of -400to 550C.
Mark the net weight of the solid dry ice on
the outside of the package in kilograms.
Place absorbent material between
primary receptacle and secondary
packaging. Examples of absorbent material
are: cellulose wadding, cotton balls, paper
towels, commercial absorbent packets.
Multiple primary receptacles must be
cushioned.
For infectious substances (column on
Place the above in an outer rigid
right): •Declare the dry ice on the
packaging. Examples are corrugated
Dangerous Goods (DG) label with complete cardboard box, rigid plastic cooler, rigid
shipping name and UN ID# UN1845. •Use plastic box. The smallest external
a Class 9 Miscellaneous DG label.
dimension must be at least 100mm. Outer
packaging must bear the UN specification
mark.
N/A
Enclose an itemized list of contents
between the secondary packaging and
outer packaging.
5
Enclose an itemized list of contents
between the secondary packaging and
outer packaging.
6
If air waybill is used, under Nature and
N/A
Quantity of goods write Biological
Substance, cat. B UN3373. Write the Name
and Telephone number of person
responsible for shipment on outside of
package or airway bill.
Write the Name and Telephone number of
person responsible for shipment on outside
of package. Write shipper and consignee
information on outside of package.
Orientation labels should be on opposing
sides.
7
Place a UN3373 diamond shaped sticker
on outside of box. Orientation labels
should be on opposing sides.
Place: 1. Proper shipping Name and UN
no. label on the outside of the package.
2.The division 6.2 Hazard Label on the
outside of the package. 3. complete
dangerous goods form.
Class 9 Miscellaneous Hazard label. Class
9 Proper Shipping Name, UN Number and
quantity label on the outside of the
package.
Packaging for Exempt Human Specimens
The following is required for shipping exempt human specimens:
• Triple packaging consisting of
• Leakproof primary receptacle
• Leakproof secondary packaging
• Outer packaging must be strong enough to safely contain
contents throughout the trasport.
• minimum size for outer package is 100mm on one surface
• Absorbent material must be placed between the primary and
secondary packaging
• Multiple primary receptacles must be cushioned
• Primary receptacles must be secured with positive means (tape,
paraffin, parafilm)
Miscellaneous General Packaging Rules
Reuse is allowed if outer shipper is in good condition
Other dangerous goods cannot be packed with infectious substances
except for:
Preservatives & transport media < 30 ml per primary receptacle
Dry ice
Packaging Consideration for Refrigerants
Types of refrigerants that may be used:
Dry ice
Gel packs or phase change material (PCM) packs
Liquid nitrogen
Wet ice
All refrigerants are to be placed outside the secondary packaging
If wet ice is used, it must be placed in a leakproof container
Dry ice must never be placed inside a sealed primary receptacle or
sealed secondary packaging due to the risk of explosion. The packaging
must permit the safe release of carbon dioxide gas.
If liquid nitrogen is used, the liquid nitrogen must be absorbed in porous
material such that there is no free standing liquid nitrogen – “dry shipper.”
Other special conditions apply when shipping with liquid nitrogen where
there is free standing liquid nitrogen in the package.
No shipper’s declaration is required if dry ice is used to refrigerate
category B substances.
Marking and Labeling
Shipping information required
Shipper information
Consignee Information
Name and telephone number of
responsible person
Appropriate hazard labels
Appropriate handling labels
Hazard & Handling Labels
Category A
Biological Substance, Category B
Exempt Human Specimen
Dry ice
Infectious substances,
affecting humans
UN2814
x ________________ mls.
Handling Labels
Orientation label for liquid dangerous goods
NEW (1/1/2013)
Cargo aircraft only – Required
when primary container of
Category A is > 50 ml
OLD
Example of a Category A Shipment Without Dry Ice
Shipper
Consignee
Responsible Person
Name & telephone No.
Infectious substances,
affecting humans
UN2814 (
)
Example of a Category A Shipment With Dry Ice
Shipper
Consignee
Responsible Person
Name & telephone No.
Infectious substances,
affecting humans
UN2814 (
mls
)
Example of a Category B Shipment Without Dry Ice
Shipper
Consignee
Person Responsible
Telephone No.
Example of Category B Shipment With Dry Ice
Shipper
Consignee
Person Responsible
Telephone No.
Example of Exempt Patient Specimen Without Dry Ice
Shipper
Consignee
Overpacks
Each package placed into an overpack must be individually marked,
labeled and addressed as if it were being shipped independently.
Once packages are placed in the overpack, the marks, labels and other
information has to be reproduced on the overpack.
Shipper
Consignee
OVERPACK
Person Responsible
Telephone No.
Shipper’s Declaration
A document called the “Shipper’s Declaration for Dangerous Goods”
must accompany every Category A package.
At least 3 copies must be must be prepared
The shipper keeps one copy
The carrier takes 2 and delivers one to the consignee
The shipper must keep the Shipper’s Declaration at least 2 years
and include the date of acceptance by the initial carrier
A Shipper’s Declaration is not required for dry ice UN 1845 unless it
is used as a refrigerant for dangerous goods which require a
Shipper’s Declaration
FedEx Requirements for Shipper’s Declaration
FedEx requires all Shipper’s Declarations to be
prepared using only the following methods
• FedEx approved vendor software application
• Preapproved shipper proprietary software, or
• FedEx Express Automated Shipping Solutions that
have dangerous goods error checks
620
954
3 Fibreboard
boxes X 150 ml
620
954
Overpack used
Emergency Response for Infectious Substances
Any person responsible for carriage or receipt of packages containing
infectious substances who becomes aware of damage to or leakage
from such a package, must:
Avoid handling the package unless wearing appropriate PPE
Inform the appropriate local Public Health authority
Notify the shipper and the consignee and person responsible
In case of incidents involving Category A Infectious substances, call
the 24-hour emergency response number indicated on the Shipper’s
Declaration
Keep unauthorized personnel away
Do not allow clean-up of the spill or disposal of the material except
under the supervision of an expert
Incident Reporting
Anyone who is in contact with a dangerous good when an incident occurs must report the incident to the
appropriate authorities in accordance with the authority’s requirements. The following information needs
to be relayed:
1.
2.
3.
4.
5.
6.
Name of reporter
Name and address of person represented by reporter
Phone number where reported can be contacted
Date, time, location of incident
The extent of injury, if any;
Class or division, proper shipping name and quantity of hazardous materials involved, if such
information is available; and
7. Type of incident and nature of hazardous material involvement and whether a continuing
danger to life exists at the scene.
Telephone reporting is required whenever:
1. A hazardous material has been directly involved in:
The death of a person
A person receiving an injury required hospitalization
The general public is evacuated for one hour or more;
A major transportation artery or facility was closed or shut down for one hour or more; or
The operational flight pattern or routine of an aircraft was altered;
2. Fire, breakage, spillage, or suspected contamination occurs involving an infectious substance
other than a regulated medical waste;
3. A situation exists of such a nature that, in the judgment of the person in possession of the
hazardous material, it should be reported to the CDC even though it does not meet the above
criteria
Detailed Incident Reports
49CFR 171.16
Each person in physical possession of a hazardous material at the time that any of the
following incidents occurs during transportation (including loading, unloading, and temporary
storage) must submit a Hazardous Materials Incident Report on DOT Form F 5800.1 within 30
days of discovery of the incident.
Examples of incidents requiring detailed incident reports
• Any of the immediate reporting incidents
• An unintentional release of hazardous material
• An undeclared hazardous material is discovered
Online copies of the report are available at: https://hazmatonline.phmsa.dot.gov/incident/
An incident report must be retained for 2 years at the reporter’s place of business. The report
must be updated within the first year if:
• A death occurs from injury caused by the hazardous material
• There was a misidentification of the hazardous material
• Additional damage, loss or related cost was incurred and not know at the time of the
incident
Security Awareness Training
Any company or institution who handles or transports dangerous goods should train any staff in contact with the
dangerous goods concerning the potential security risks associated with the dangerous goods.
Dangerous goods should only be offered to operators that have been appropriately identified.
This training should include all aspects of security risks including:
• Nature of the risks
• Recognition of risks
• Practices used to reduce risks
• Procedures for a security breach
Security training must be in accordance with a national security plan or equivalent level of training
Initial training for hazmat employees should occur within 90 days after employment
Recurrent training should be performed whenever there are changes to the security protocols or at least every 2
years and the employer must retain records of security training
The following are suggested areas for security awareness and best practices:
Restrict access to dangerous goods only to trained and qualified staff
Escort visitors and other unauthorized personnel
Record entry into sensitive areas and the purpose of the visit
Record the identity of the escort and the times of entry and exit
Ensure that doors and cabinets are locked when staff is not present
Monitor area remotely when staff is not in the area
Protect the chain of custody by using tamper-evident methods as it relates to your package
Create an audit trail for specimens
Consider using serialized packaging
Security Plan
Any shipper or operator who handles and/or transports Category A infectious substances should adopt a
security plan to guard against potential incidents.
The security plan must include an assessment of transportation security risks for shipments of
hazardous materials, including site-specific or location-specific risks associated with facilities where the
hazardous materials are prepared for transportation, stored, or unloaded incidental to movement, and
appropriate measures to address the assessed risks.
At a minimum, the security plan must include:
Measures to confirm information provided by job applicants hired for positions that involve access
to and handling of the hazardous materials covered by the plan
Measures to address the assessed security risks of shipments of dangerous goods covered by
the security plan enroute from origin to destination, including shipments stored incidental to
movement.
Identification by job title of the senior management official responsible for overall development and
implementation of the security plan.
Security duties for each position or department that is responsible for implementing the plan or a
portion of the plan and the process of notifying employees when specific elements of the security
plan must be implemented.
A plan for training dangerous goods employees in accordance with the regulations.
Security Plan, Continued
The security plan must include:
Transportation security risk assessment
Be in writing
Be reviewed annually and revised/updated as necessary
Be available to employees who are responsible for implementing it
and be consistent with personnel security clearance or
background investigation restrictions and a demonstrated need to
know
Notification of employees when the plan is updated or revised
Be available to appropriate officials when requested
References
IATA Dangerous “Goods Regulations, 52 Edition, Canada, 2011
SafTPak, Compliance Training Reference Manual for the Safe Transport
of Division 6.2 Infectious Substances, Biological Specimens, Dry Ice and
Related materials, Edmonton, Alberta, 2011
Federal Register / Vol. 71, No. 106 / Friday, June 2, 2006 / Rules and
Regulations, 49CFR 172.101