From:
George Walton <georgewalton548**At_Symbol_Here**GMAIL.COM>
Subject:
Re: [DCHAS-L] Fwd: Safe Transportation Recommendations; 2018
Date:
May 20, 2024 21:08 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<CAEyQULU0xOShf1QqFywYG84Nx9T2=zoFw75uZztjn76CrsFvGw**At_Symbol_Here**mail.gmail.com>
In-Reply-To:
<CAKoY-_yAr07OEiMw6oq-RMwSp13VPEctFu1OJ0h+sd4GYTex_Q**At_Symbol_Here**mail.gmail.com>
I believe materials of trade are essentially for private carriers. A painting company owns a company truck and has a company employee operating that vehicle. The company owns some solvent or paint that is a hazardous material. If the company owned truck is operated by a company employee and carries a hazardous material that the company will use in the course of its business, then a the hazardous material transportation falls under materials of trade.
For instance, if Case Western is going to a river to collect samples and the samples, after preservation, will be transported to Case Western for analysis, then the preservative (assuming it is a hazard0us material) falls under the materials of trade exemptions. (Case Western owned vehicle, Case Western employee loads and operates the truck, Case Western employee unloads the truck -- materials of trade) If Case Western is preparing for a science fair and ships a hazardous material by FedEx, UPS, etc, then the shipment is NOT eligible for the materials of trade exemption (Case Western doesn't own the truck, doesn't employ the driver). If Case Western is using a university owned vehicle operated by a Case Western employee, then the shipment can be eligible for a materials of trade exemption. Use a CURRENT 49 CFR 173 (issued in October 2023) for package limits and shipment limits. There are volume and weight limits.
Can you shed some light on my question or direct me to the department that can?
Thank you
Mary Ellen
Hello,
I am contacting you to clarify information on shipping hazardous materials for science fairs.
I have attached an ACS publication and would like to use this process. I agree with the interpretation that these chemicals are part of research or education, which is our business.
I teach shipping and have asked our official training organization about using this application. The feedback was that chemicals for educational purposes would not fall under 173.6 MOT because they are not materials that support a business's operation.
' MOT is used for companies that, during the course of their business, have hazardous material in their vehicle as a principal product that supports the function of their business. Examples include painters, roofers,
and lawn care companies.'
Has there been any update to the ACS recommendations for chemicals used in demonstrations or educational activities? This area seems to be open to interpretation.
Thank you for your time and help.
Mary Ellen Scott
Mary Ellen Scott, Ph.D., CIH, CSP
Case Western Reserve University
EHS - Environmental Health and Safety
Service Building 1st Floor Rm 113
2220 Circle Dr.
Cleveland, OH 44106-7227
216-368-6077
216-368-2236 (Fax)
maryellen.scott**At_Symbol_Here**case.edu"
There is no science without fancy and no art without fact" – Vladimir Nabokov
(1899-1977).
Mary Ellen Scott, Ph.D., CIH, CSP
Case Western Reserve University
EHS - Environmental Health and Safety
Service Building 1st Floor Rm 113
2220 Circle Dr.
Cleveland, OH 44106-7227
216-368-6077
216-368-2236 (Fax)
maryellen.scott**At_Symbol_Here**case.edu“There is no science without fancy and no art without fact” – Vladimir Nabokov
(1899-1977).
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