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Previous by Date: Subject: Re: [DCHAS-L] 2017 CHAS Awards and CHAS Fellows Date: Wednesday, December 7, 2016 at 1:53:29 PM Author: "Wilhelm, Monique" <mwilhelm**At_Symbol_Here**UMFLINT.EDU> |
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Materials of trade exceptions are useful for many scenarios of commercial transportation of hazardous materials. 49 CFR 171.1 is more pertinent in this case and
I believe what Ed was referring to; it states that DOT regulates transportation of materials transported “in-commerce”. There are several letters of interpretation from DOT describing how activities undertaken by state agencies, including state universities,
are not considered commercial activity and are not subject to Hazardous Materials Regulations. For large lab moves, we often hire vendors (who are regulated by DOT) to move the chemicals because it is simply the best option from a staffing perspective.
Andy Glode
Laboratory Safety Officer
Environmental Health and Safety
University of New Hampshire
Durham, NH
603-862-5038
http://www.unh.edu/research/environmental-health-and-safety
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU]
On Behalf Of Russ Phifer
Sent: Wednesday, December 07, 2016 1:14 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Moving labs in University
I agree with Ed; the specific regulatory reference is the Materials in Trade Exception (49CFR 173.6). You do not need to hire a “licensed” company to transport hazardous materials
from one of your facilities to another, or across campus. You do need to utilize DOT packaging if you are going on public roads, and need a hazardous materials bill of lading (available online or in office supply stores) to accompany the load.
This exemption also applies to field studies (stream sampling, for instance) and to Chem Week type chemistry demonstrations at shopping malls and other public places.
Hazardous waste transport is not allowed under this exception, but you can transport hazardous waste around your campus as long as you are crossing public roads but not going
onto public roads.
Russ
Russ Phifer
WC Environmental, LLC
1085C Andrew Drive
West Chester, PA 19380
Fax 800-858-6273
Cell - 610-322-0657
rphifer**At_Symbol_Here**wcenvironmental.com
http://www.wcenvironmental.com
P
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From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU]
On Behalf Of Edward Movitz
Sent: Wednesday, December 07, 2016 12:38 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Moving labs in University
A government employee, transporting government owned material, from one government location to another government location, either on public roads or not, is not subject to any DOT regulations.
WVU employees can load a WVU truck with WVU chemicals (carefully) and drive to any other WVU campus.
DOT regulates transportation in commerce, and the government transportation of government materials as described above is not a commercial activity.
Ed
Edward M. Movitz
Research & Environmental Compliance Officer / FSO
The University of Mississippi
Laboratory Services
100 Health and Safety Building
P.O. Box 1848
University, MS 38677-1848
U.S.A.
O:+1-662-915-5433 | F: 662-915-5480
movitz**At_Symbol_Here**olemiss.edu |
www.olemiss.edu
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Laboratory
Services Web Site
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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
on behalf of Barbara Foster <bfoster**At_Symbol_Here**WVU.EDU>
Sent: Wednesday, December 7, 2016 11:10 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Moving labs in University
You don’t mention the specifics on distance and/or routes, but you have to follow all DOT regs when transporting hazardous materials on roadways. You will have to hire a licensed
company to move hazardous materials across campus.
Barbara L. Foster
College Safety Officer
Eberly College of Arts and Sciences
West Virginia University
DCHAS Fellow - American Chemical Society
304-293-2729 (desk)
304-276-0099 (mobile)
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU]
On Behalf Of Fu, Zhen
Sent: Wednesday, December 07, 2016 10:01 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] Moving labs in University
Hi all,
Could you please share the policy or procedures on moving batch of chemicals within university from one building to the other? What EHS’s role on this matter?
Thank you,
Zhen
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