Compliance with Federal Hazardous Materials Shipping Regulations

On 3/22/2011, Philip Hanlon, Timothy Slottow, and Stephen Forrest sent the following message to deans, directors, and department heads:

The U.S. Department of Transportation – Federal Aviation Administration (FAA) has recently notified the University of potential violations of Federal hazardous materials shipping regulations. Several packages containing dry ice have been caught during random inspections at Detroit Metro Airport without the required identity of contents and proper labeling. Dry ice is regulated as a hazardous material when offered for shipment through a carrier like UPS.

The researchers who prepared the non-compliant packages for shipment were untrained and unaware of shipping requirements and associated paperwork. Thus far, the University has not been fined because we offer outreach and training to the research community. However, since this situation has occurred several times recently, we believe the FAA will not continue to view such transgressions leniently. Penalties for failure to comply with hazardous materials shipping regulations can be severe, and both institutions and individuals may be held liable.

There has been increased scrutiny of hazardous material shipping by state and federal agencies over the past several years due to the threat of terrorism, and we are aware of several other universities that have recently been cited for failure to comply with FAA regulations.

Any campus employee who intends to ship hazardous materials including biological specimens, with or without dry ice, must be trained on the appropriate methods of preparing packages, labeling, marking, and manifesting. This includes those who prepare paperwork for hazardous materials shipments and those who pack the parcels for shipment. Occupational Safety and Environmental Health (OSEH) offers certification training for shippers of hazardous materials, including dry ice. For questions or to sign up for training, please call (734) 763-6973 or visit the OSEH website at ww.oseh.umich.edu.

We urge you to share this message with all of principal investigators and key staff members who might ship regulated hazardous materials to help make them aware of this regulatory risk.