Does the transport take place along roads to which the general public has vehicular access without restraint?  (i.e. there are no gates or barriers to entry) If so, my response, based on what I concluded for a campus-like industrial facility, would be to say that the Hazardous Materials Transportation Regulations of the DOT apply.  That includes training of employees involved but can also take advantage, in some cases, of reduced requirements based on the smaller size of the containers involved, including the often useful “Materials of Trade” exception. But note that 20-L and 4-L containers are NOT bulk transports under the DOT regulations.  Does your mail room open the packages before passing them along?  If so, resealing them may have very specific requirements if DOT regulations apply.

If your campus roads are inaccessible to the general public and their vehicles without specific permission for each entry, then DOT regs will not apply, but I would suggest looking at them anyway as an upset is still an upset  and one purpose of the regulations is to be reasonably confident that those who need to know have ready access to information when there is an upset.

Peter Zavon, CIH
Penfield, NY

PZAVON**At_Symbol_Here**Rochester.rr.com

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