Office of Research and Sponsored Programs
1111 West 17th Street
Tulsa, OK 74107-1898
918-561-1400
Fax 918-561-1416
Hazardous Materials/Dangerous Goods Shipping Policy
1.0
PURPOSE
Universities and colleges nationwide are experiencing increased scrutiny of their hazardous materials (HM) and
dangerous goods (DG) shipping practices. At the same time HM/DG shipping requirements are becoming more
and more complex. In several recent cases, campuses have been penalized with fines for errors in their
shipments and documentation. To serve OSU employees and students, the Office of Research is working to
make compliant shipping easier.
2.0
SCOPE
Any OSU-CHS employee or student who wants to transport HM/DG is affected by international, federal, state,
and local regulations. For example:
 A researcher sending samples to collaborating persons at other research, hospital or teaching institution,
 A researcher forwarding materials to a field station for an upcoming project,
 Administrative personnel returning or forwarding an order
HM/DG includes hazardous substances, and in some instances includes goods or equipment contaminated with
hazardous substances.
This policy does not apply to hazardous chemical wastes, radioactive wastes, or biohazard wastes offered for
shipment in commerce.
3.0
DEFINITIONS
Hazardous material (HM) is defined as a substance or material capable of posing an unreasonable risk to health,
safety and property when transported in commerce. Materials that are hazardous to the environment (i.e.,
hazardous substance, hazardous wastes, and marine pollutants) are also regulated. The terms hazardous
materials and dangerous goods are often used interchangeably when discussing shipping. HM regulations may
apply to commercial products, chemical mixtures, items containing or contaminated with hazardous substances,
and newly synthesized compounds. Hazardous materials include, but are not limited to laboratory, maintenance,
and agricultural chemicals; biological agents; radioactive materials; compressed gases; patient specimens; dry
ice; refrigerants and related equipment; instruments/equipment that contain hazardous materials. There are nine
classes of HM:
Page 1 of 4
Class No.
None
None
1
1
1
1
1
1
2
2
2
3
4
4
4
5
5
6
6
7
8
9
None
4.0







Division No.
(if any)
1.1
1.2
1.3
1.4
1.5
1.6
2.1
2.2
2.3
4.1
4.2
4.3
5.1
5.2
6.1
6.2
Name of class or division
Forbidden materials
Forbidden explosives
Explosives (with a mass explosion hazard)
Explosives (with a projection hazard)
Explosives (with predominately a fire hazard)
Explosives (with no significant blast hazard)
Very insensitive explosives; blasting agents
Extremely insensitive detonating substances
Flammable gas
Non-flammable compressed gas
Poisonous gas
Flammable and combustible liquid
Flammable solid
Spontaneously combustible material
Dangerous when wet material
Oxidizer
Organic peroxide
Poisonous materials
Infectious substance (Etiologic agent)
Radioactive material
Corrosive material
Miscellaneous hazardous material
Other regulated material: ORM-D
49 CFR reference for
definitions
173.21
173.54
173.50
173.50
173.50
173.50
173.50
173.50
173.115
173.115
173.115
173.120
173.124
173.124
173.124
173.127
173.128
173.132
173.134
173.403
173.136
173.140
173.144
AGENCIES THAT REGULATE HAZARDOUS MATERIAL/DANGEROUS GOODS SHIPPING
International Air Transport Association (IATA)
U.S. Department of Transportation (DOT)
Oklahoma Highway Patrol (OHP)
U.S. Department of State, Directorate of Defense Trade Controls (DDTC)
U.S. Department of Commerce, Bureau of Industry and Security (BIS)
U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
U.S. Customs & Border Protection (CBP)
Depending upon material quantity and type, restrictions may apply even to HM being moved to and from offsite facilities during research activities. International shipments have even more complex restrictions with very
serious consequences for errors.
H a z a r d o u s M a t e r i a l s / D a n g e r o u s G o o d s S h i p p i n g P o l i c y
O S U - C H S O f f i c e o f R e s e a r c h , v e r s i o n N o v . 2 0 1 3
Page 2 of 4
5.0
RESPONSIBILITIES
OSU Employees and Students: Anyone wanting to send a HM off site is responsible for accurately identifying
the material and any known hazards associated with the item(s) and must follow all applicable regulations.
Office of Research: The Office of Research is available to provide guidance regarding shipping policies and
regulations. If the campus is subject to an inspection, Office of Research personnel will liaison with the
inspector(s).
6.0



ACTIVITIES THAT CONSTITUTE HAZARDOUS MATERIAL/DANGEROUS GOODS SHIPPING
Mailing an HM off campus, out of state or out of the U.S.
Shipping an HM off campus, out of state, or out of the U.S. via a carrier such as FedEx, UPS, Express
Mail, etc.
Carrying an item with you when you travel, for example, on an airplane.
In addition, any time an individual moves or sends a HM from one location to another, he or she is potentially
shipping a material. When in doubt, contact the Office of Research.
7.0
INTERNAL OSU TRANSPORT
The transport of hazardous materials by OSU employees or students, either in person or when using University
or private vehicles, solely for non-commercial University purposes is exempt from DOT regulations but not this
policy. Transport of hazardous materials by University employees or students may only be conducted when the
following conditions or requirements are fulfilled:
 Only small amounts or limited quantities are allowed. The maximum net quantity (weight or volume)
must be less than the amount allowed on a passenger aircraft (see IATA section 4.2 List of Dangerous
Goods, column J).
 The material must be in appropriate, leak-proof containers or packaging.
 Secondary containment is to be used to contain any spill of the hazardous materials being transported.
 Incompatible materials are to be separated into different secondary containers.
 When in a vehicle, hazardous materials are to be transported in the trunk, or as far away from passengers
as possible.
 All containers are to be clearly labeled with content information and include applicable Safety Data
Sheets or precautionary instructions (e.g. warning labels for pesticides, controlled substances, etc.).
 Materials and supplies, including personal protective equipment needed to contain or clean up a spill are
to be available in the vehicle.
 Individuals transporting hazardous materials must either carry a method of communication should a spill
or release occur or be accompanied by another individual.
 The individual transporting hazardous materials must be trained and familiar with each material's
hazards, the precautionary measures to avoid those hazards, and procedures to contain or clean up a
spill. It is strongly recommended that individuals new to transporting hazardous materials, or
transporting new or different materials consult with Office of Research staff to insure they have
appropriate knowledge, training, and materials to safely transport hazardous materials.
H a z a r d o u s M a t e r i a l s / D a n g e r o u s G o o d s S h i p p i n g P o l i c y
O S U - C H S O f f i c e o f R e s e a r c h , v e r s i o n N o v . 2 0 1 3
Page 3 of 4
8.0
IMPORT/EXPORT
Persons importing dangerous goods into the United States must provide the shipper and forwarding agent at the
place of entry with information regarding the requirements of the Hazardous Materials Regulations (49 CFR
Subpart C) applicable to the shipment while in the United States.
Persons exporting dangerous goods from the United States must comply with the common carrier's
requirements and any applicable regulations of the foreign country.
9.0
TRAINING
All shipping of hazardous materials as defined by regulatory agencies or shipping companies must meet the
comprehensive training requirements imposed by the International Air Transport association (IATA), the
Department of Transportation (DOT), the Oklahoma Highway Patrol (OHP), the Directorate of Defense Trade
Controls (DDTC), the Bureau of Industry and Security (BIS), the Office of Foreign Assets Control (OFAC),
and additional organizations.
Training is required to legally package and ship HMs. Personnel who offer shipment by ground (per DOT
regulations) must receive refresher training every 3 years. Those who ship by air must receive refresher training
every 2 years (per IATA regulations).
Because of the training necessary and the continual changes in the regulations, Office of Research staff have
been trained to be in regulatory compliance. If a lab/department will be shipping alike samples (same organism,
same approximate quantity, same method of preservation) routinely (more frequently than every 3 months),
Office of Research will train 1 or 2 personnel to be in compliance with the regulations as they pertain to just
that sample shipment.
10.0 PROTOCOL
Sending packages through the Office of Research will protect the individual and the University from serious
consequences. The trained and certified staff of the Office of Research will assist with packaging samples. They
will ship HM, however, the OSU employee or student is still responsible for the accurate description of
materials. Individuals shipping HMs are required to comply with the specifications of the regulations including:
Those who prepare and send HM for shipment must receive initial and periodic training,
and
HM shipments must be properly classified, described, packaged, marked, and labeled.
Notify the Office of Research of shipments at least 2 business days before a package needs to be shipped. More
notice may be needed for international shipments to make sure that all necessary packing materials, labels and
shipping documents are available and completed accurately.
11.0 PENALTIES FOR NON-COMPLIANT SHIPPING
Intentional disregard or deliberate noncompliance with this University policy by any student or employee may
result in University corrective or disciplinary action. Failure to comply with 49 CFR may result in penalties for
OSU and/or an employee. OSU may be subject to civil penalties that can range from $275 to $55,000 per
violation per day. Individuals can be subject to criminal penalties for knowing and willing violations. Such
penalties can range up to $250,000 and if found guilty, an individual may face up to ten years in prison.
H a z a r d o u s M a t e r i a l s / D a n g e r o u s G o o d s S h i p p i n g P o l i c y
O S U - C H S O f f i c e o f R e s e a r c h , v e r s i o n N o v . 2 0 1 3
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