DCHAS-L Discussion List Archive
Date: Fri, 26 Jun 2009 07:33:09 -0500
Reply-To: Beth Shepard <Beth.Shepard**At_Symbol_Here**SIAL.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Beth Shepard <Beth.Shepard**At_Symbol_Here**SIAL.COM>
Subject: Re: Sharing Chemicals w/Thailand Research Lab
Good morning--
While Rob is correct in that a material is hazardous or not, regardless of
quantity, from a health & safety perspective, some of the transportation
regulations do vary with quantity of material in how packages have to be
packed/marked/labeled. For example, the DOT has a small package exception
for <=30ml or g of materials in certain hazard classes.
Beth
Technical Compliance Specialist
Sigma-Aldrich Corp.
6000 N. Teutonia Ave.
Milwaukee, WI 53209
414-438-2608, x 5471
It the chemicals meet the OSHA definition of hazardous, then they are
required to have MSDS's (with a few exceptions, none of which apply here):
http://www.ilpi.com/msds/ref/hazardous.html
http://www.ilpi.com/msds/faq/partb.html#required (the exceptions)
"Hazardous" is an intrinsic property of a material. A material is
hazardous or it is not, the amount does not matter. Risk is an extrinsic
property as it varies with the amount of the material:
http://www.ilpi.com/msds/faq/partb.html#minquantity
When shipping research quantities of chemicals that you have created, then
you are required to have MSDS's to accompany the shipments:
http://www.ilpi.com/msds/faq/partc.html#laboratory and references therein
If the materials are hazardous, the Post Office will generally not touch
them:
http://pe.usps.com/text/qsg300/Q601.htm
UPS and FedEx are your best bets, but keep in mind that normal mortals can
not ship HazMat - the shipper of HazMats has to be certified in order to
do that:
http://www.ups.com/content/us/en/resources/ship/hazardous/index.html
http://fedex.com/us/services/options/hazmat/
I have a contact who has made regular trips to Thailand and collaborated
with chemists there. He's probably done what you need to do and may be
able to offer specific advice. I will send you his information by private
mail.
Rob Toreki
On Jun 25, 2009, at 2:11 PM, Mary Cavanaugh wrote:
Hello all, we have a new situation here on which I hope some of you can
advise me.
One of our chemists has about a dozen chemicals used for research that
need to be sent to a collaborating chemist in Thailand.
The chemicals are not new, all have been used in their research here in
the US, and they have no real commerical value. The quantities are all
small (50 g or less).
All the chemicals have "non-hazardous" DOT/IMDG and IATA labels and are in
their original bottles.
All are solid or crystalline at room temp except triethanolamine, which is
a viscous liquid.
What considerations do we need to have in shipping these chemicals to
Thailand? For example:
- What kind of container can we use to ship them in?
- Is IATA what applies, or do we need to look elsewhere to see if
maybe Thailand may regulate them for import or transport?
- Can we ship them in US Mail, UPS, FedEx, or anything we want?
- Are there special permissions or forms we have to obtain or
send to Thailand? (I’m already working with our Export Controls Officer).
- Do we need to acct for them on our waste manifests in some way?
- Do we need to include the MSDS for each one in the shipment,
even though we didn’t manufacture them?
Thanks in advance. I’d especially love links to any guidances that may
address this.
-mm
Mary M. Cavanaugh CIH
University Industrial Hygienist
Safety & Workers' Comp. Office
cavanaughmm**At_Symbol_Here**appstate . edu
(828) 262-6838 Direct
(828) 262-2936 Fax
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