Difference between revisions of "Shipping and Handling of Dangerous Goods"

Revision as of 17:39, 20 April 2021

Statement of Purpose

The shipping and import of of preserved natural history objects is regulated by a variety of national and international laws, such as customs law, animal and plant health regulations, and dangerous goods regulations. An overview about the different legal areas and respective training materials are added at the end of this page under Conference Presentations & Training Modules. This page will focus on the shipping and handling of Dangerous Goods.

Most collection holding natural history institutions, as part of their daily operating procedures deal with the shipping of specimens, through loans and gifts of material to other institutions as well as the accepting of incoming material. A large number of these shipments contain flammable or hazardous solutions e.g. ethanol, isopropanol or formaldehyde in varying concentrations.

Dangerous goods regulations, most in place long before September 11th, 2001, were brought sharply into focus after that tragic event. The shipping and handling of natural history specimens in wet collections has been affected by the more rigorous enforcement of these regulations, which has impacted the methods and frequency with which museums and other collection-holding institutions can send loans and gifts of materials to others. There is a great deal of confusion concerning the application of these regulations which along with a lack of knowledge has resulted in serious misinterpretations of the regulations within the natural history community.

Most alcoholic specimen shipments (as long as no other permitting or documentation restrictions apply), whether domestic or international, are sent by airmail to minimize the length of time specimens are exposed to the hazards of transport, thereby reducing the chances of damage and dehydration. Shipping dangerous goods by air presents particular problems. International shipments must comply with both the International Civil Aviation Organization (ICAO) technical instructions as well as national regulations. In order to meet commercial standards, shippers are also required to meet the International Air Transport Association (IATA) Dangerous Goods Regulations. Furthermore, some countries have added variations to many of these requirements.

Contributors

Andrew Bentley

Regulating agencies

The ICAO governs the implementation and adoption of standard aircraft shipping and packaging regulations by both the Department of Transportation (DOT) in the United States and IATA internationally. DOT regulations are unique to the United States. Other countries have similar domestically enforced regulations while a large number rely on IATA regulations for both domestic and international regulations. Domestic shipments sent through the mail within the United States must also conform to United States Postal Service (USPS) regulations while courier shipments (FedEx, UPS and DHL) must conform to the individual company’s specific regulations (which for the most part follow DOT or IATA regulations). USPS and private courier regulations must meet or exceed the DOT or IATA regulations respectively; in many instances they are more restrictive.

Training

Current regulations exempt all natural history packages from dangerous goods regulations (they are exempt from the regulations but still need to be packed according to the regulations), there is no need to obtain formal dangerous goods training and one can self-train using the regulations as a guide.

See Conference Presentations & Training Modules section below to access SPNHC workshop training materials on shipping dangerous goods as well as US and international customs regulations pertaining to natural history specimens.

See the Discussion page for regulations prior to 2014.

Dangerous goods/Hazardous materials

Dangerous goods/hazardous materials are classified according to Hazard Class and Packing Group. For example, most flammable liquids fall into Hazard Class 3 (flashpoint of less than 60.5° C or 141° F). Within Hazard Class 3, materials are classified into three Packing Groups:

1. Materials in Packing Group I, considered the most dangerous, have a boiling point less than or equal to 35° C (95° F).
2. Materials in Packing Group II, considered moderately dangerous, have a boiling point above 35° C (95° F) and a flashpoint less than 23° C (73° F).
3. Materials in Packing Group III have a boiling point above 35° C (95° F) and a flashpoint between 23° C (73° F) and 60° C (140° F).

Of the four substances most commonly used in wet collections only ethanol, isopropanol and formaldehyde are covered under dangerous goods regulations. Glycerin (glycerol) used for cleared and stained specimens, is not regulated in any concentration.

Table 1: Flash Points of Ethanol based Water Solutions

Ethanol (ethyl alcohol), most commonly used in concentrations of 70% and above, is regulated for transport. Concentrations between 10% and 80% fall into Packing Group III while concentrations above this fall into Packing Group II.

Table 2: Flash Points of Isopropanol based Water Solutions

Isopropanol (isopropyl alcohol), most commonly used at concentrations of 50% and above, falls into Packing Group III at concentrations of 10 to 30% while concentrations above this fall into Packing Group II.

Formaldehyde (formalin), usually sold as a saturated solution of formaldehyde gas in water and measured by weight or volume concentration, is most commonly used in concentrations of 3.7% or 4.0% (what is called 10% formalin in natural history collections) and is unregulated for transport. Above 10% is a Class 9, packing group III substance and is regulated for transport.

Other solutions used in tissue storage include:

• dimethyl sulfoxide (DMSO) - unregulated in any concentration
• propylene glycol - unregulated in any concentration
• RNAlater - proprietary (of unknown composition, although thought to be made up primarily of propylene glycol), is not listed as a dangerous good.

The shipment of infectious substances, natural history specimens not containing dangerous goods (pinned insects, skins, skeletons etc.), biological materials other than natural history specimens and any material on dry ice is covered by a separate set of regulations, and is not discussed here. There may also be ancillary permitting/documentation requirements for the domestic or international transfer of biological specimens (U.S. Fish and Wildlife import/export or CITES permits, APHIS, etc.). APHIS in particular has specific approved treatment methods required for import of specimens of avian, ruminant, equine and swine. These regulations (when relevant) should be adhered to during the transport of any natural history materials.

Regulations

Domestic and international shipping and packing guidelines vary slightly in scope and limitations but both include special dispensations for smaller quantities of dangerous goods. The two sets of limited quantity regulations are very similar in scope and content but have a number of limitations that must be adhered to. It is important to consult the original texts of both the DOT and IATA regulations before shipping. USPS and DOT regulations are available online1,2 while IATA regulations must be purchased.

Domestic Regulations

In the United States, the shipment of dangerous goods (referred to as hazardous materials) are covered in DOT Title 49 CFR (Parts 100 to 185)^[1] and USPS Publication 52^[2]. An exception to the regulations is made for dangerous goods in restricted quantities termed “small quantity regulations” outlined in DOT 173.4 and USPS Publication 52 (3.34). These small quantities are considered exempt from regular DOT and USPS hazardous goods requirements. Most fluid preserved natural history specimens can be packed and shipped utilizing these small quantity regulations. Institutions in other countries should consult their national dangerous goods regulations to ascertain if similar regulations exist and ensure compliance. In some instances this may mean using IATA regulations as outlined below in the international section of this document. Outlined below are the important relevant points from the DOT and USPS regulations:

1. Small quantities may be sent through the United States Postal Service via air transportation (Express, Priority and First-Class mail) or surface transportation as Standard or Parcel Post, or by any of the three major courier companies (FedEx, UPS and DHL) that follow DOT 49 CFR 173.4 small quantity regulations.

2. Class 3 dangerous goods (all packing groups) are acceptable (ethanol and isopropanol).

3. The maximum quantity of dangerous goods per inner receptacle cannot exceed 30 mL for acceptable liquids (as above). This inner receptacle cannot be liquid full at 55°C (131°F) and is to be constructed of plastic (having a minimum thickness of 0.2mm), earthenware, glass, or metal. A removable closure on an inner receptacle must be held securely in place using wire, tape or other positive means.

4. Each inner receptacle must be placed within a securely sealed secondary package.

5. Sufficient cushioning and absorbent material (that will not react chemically with the dangerous goods) must surround each inner receptacle and be capable of absorbing the entire contents of the receptacle.

Figure 1: Example of appropriate labeling

6. The secondary packages must be securely packed in a strong outer package (box) which complies with DOT mandated drop and compressive load tests without breakage or leakage from any internal receptacle:

a. Drop tests – free drop on top, bottom, long and short side and the junction of three sides of the package from 1.8m (5.9 feet) onto a solid unyielding surface.

b. Compressive load test – stack packages of similar size and weight to a height of no less than 3m (10 feet) for 24 hours.

7. The gross mass of the package must not exceed 29 kg (64 pounds).

International Regulations

International Customs Requirements

Shippers parcels that are transported internationally and im- or exported through national border inspection posts need to be accompanied by detailed data to allow customs clearance of parcels. Such data is usually handled in electronic systems such as the EU-wide Import Control System 2 (ICS 2) and either transmitted immediately as soon as collection staff issue shipments e.g. by using web-based shipping software solutions offered by FedEx/UPS/DHL Express, or entered by companies handling the parcels before export and loading onto aircraft.

Proper customs declarations help to avoid import delays and damage to specimens. Staff tasked with issuing parcels should make sure that the following data is entered correctly into electronic systems and on written air waybills if these are issued (e.g. when sending international parcels through national postal carriers):

1. Description of goods: preserved museum specimens (+ detailed description = preserved freshwater fish/dried herbarium specimens/dried insects/etc.)
2. Description of preservatives: e.g. 75 % denatured Ethanol (UN1170, PG II)
3. Customs tariff code for preserved museum specimens is: 9705.00
4. Details of shipper & consignee, including phone & email contacts
5. Customs Identification number (if available): e.g. for EU-collections, this is the EORI-number (Economic Operators' Registration and Identification number)

Two things should be avoided:

1. "Scientific specimens" as proper description in declarations or commercial invoices - this inclusive general term which could also covers unpreserved, fresh infectious materials like blood or feces samples red-tapes parcels and often triggers close inspection by veterinarian authorities and/or customs
2. Parcels shipped from universities are intercepted frequently at international borders for checks. Therefore, university-based natural history collections and similar institution shipping preserved, dead museum objects mention the name of the collection in the shippers address first, followed by their university affiliation (e.g. Natural History Museum, XY University).

Boilerplate for Proforma Invoice / Customs Declaration:

This package contains dead museum specimens (preserved freshwater fish; for Latin species names refer to included loan agreement) for scientific research, which were originally preserved in formalin solution (max. strength: <10%, UN2209) for at least one week and then transferred into 75% denatured Ethanol (UN1170, PG II) for further preservation. Preserved specimens packed are not subject to the initial selection list of products for veterinary checks at border inspection posts under Art. 3 Council Directive 2007/275/EC, Annex I, EX 9705 00 00). Preservation of specimens agrees with requirements for SAFE TREATMENT laid down in Point (8) (a) (e) (ii) in the ANNEX to the Commission Regulation (EU) No 294/2013, amending Commission Regulation (EU) No 142/2011, ANNEX XIII, CHAPTER VI. The specimens are on loan for biodiversity (morphological /taxonomical) research and legally belong to the State of Bavaria (Country of Origin: Germany); they are non-infectious, non-contagious, non-venomous, unfit for human consumption, no traded goods, have no commercial value and are not for resale.

HS-Code: 9705.00 (Collections of zoological / botanical / mineralogical archaeological / paleontological interest)
Declared value: 5.00 €

Dangerous Goods Regulations of the International Air Transport Association (IATA)

International shipments of dangerous goods are covered in Section 2.7 ^[3] of the IATA regulations. As above, restricted quantity regulations exist for international shipping, contained in IATA Section 2.7.1 and referred to as “Dangerous Goods in Excepted Quantities”. Dangerous goods in excepted quantities, in contrast to DOT and USPS regulations, are considered dangerous goods under IATA regulations but are exempt from large portions of the dangerous goods regulations applicable to larger quantities.

With the USPS letter of interpretation, packages can now be sent internationally as long as they conform to the requirements of the International Mailing Manual (IMM). The IMM lists requirements by country including lists of prohibited materials. As long as flammable liquids or preserved animals or plants do not appear on the list then the USPS can be used to ship materials.

1. Class 3 dangerous goods (all packing groups) are acceptable.
2. As above, each inner receptacle may not contain more than 30 mL while the same construction, liquid full and closure security regulations apply.
3. Each inner receptacle must be placed within a securely sealed secondary package.
4. Sufficient cushioning and absorbent material (that will not react chemically with the dangerous goods) must surround each inner receptacle and be capable of absorbing the entire contents of the receptacle.
5. The same package drop and compressive load test regulations as above apply.
6. IATA regulations state that each inner receptacle must be placed within a securely sealed secondary packaging the total contents of which may not exceed 500 mL for Packing Group II liquids and 1 liter for Packing Group III liquids.

In 2011, new regulations were put in place in the IATA Dangerous Goods manual that specifically addresses natural history specimen shipments. This is an amendment termed IATA SP A 180 which states:

A180 – Non-infectious specimens, such as specimens of mammals, birds, amphibians, reptiles, fish, insects and other invertebrates containing small quantities of UN 1170, UN 1198, UN 1987, or UN 1219 are not subject to these Regulations provided the following packing and marking requirements are met:

(a) specimens are:

1. wrapped in a paper towel and/or cheesecloth moistened with alcohol or an alcohol solution and then placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30ml; or

2. Placed in vials or other rigid containers with no more than 30ml of alcohol or an alcohol solution;

(b) the prepared specimens are then placed in a plastic bag that is then heat-sealed;

(c) the bagged specimens are then placed inside another plastic bag with absorbent material then heat-sealed;

(d) the finished bag is then placed in a strong outer packaging with suitable cushioning material;

(e) the total quantity of flammable liquid per outer packaging must not exceed 1L; and

(f) the completed package is marked ”scientific research specimens not restricted Special Provision A 180 applies”.

The words “not restricted” and the special provision number A180 must be included in the description of the substance on the Air Waybill as required by 8.2.6 when an Air Waybill is issued.

All three major courier services (FedEx, UPS and DHL) accept dangerous goods in excepted quantities for international delivery and waive their normal dangerous goods surcharges for packages containing excepted quantities. All three couriers do, however, only accept dangerous goods on a contract or pre-approval basis and will only accept dangerous goods in boxes (no envelopes). FedEx has the added stipulation that the box must measure at least 7” x 4” x 4”. All three companies will only ship dangerous goods to approved countries as there are various countries within which they are prohibited from shipping (due in part to these countries not adopting IATA dangerous goods regulations for domestic transport). This means that the courier could deliver a package to the designated international airport but no further. There are also various countries where the shipment is allowed but only to certain regions or postal codes. The list of countries to which this applies changes constantly therefore the courier should be contacted for an up-to-date list4,5,6. It should also be noted that in some countries, additional customs, veterinary, or fish and wildlife fees may be incurred which will need to be paid by the recipient of the package. The list of these fees and to which countries they apply is not available or, in most cases, unknown to the courier.

All couriers have deemed natural history specimens as exempt from their “whole dead animals” mandate and as such all will carry such shipments.

Transport in personal baggage as carry-on or checked luggage

With so many variables and so many different people and organizations to deal with, there are inevitably differences in interpretation of regulations--for these reasons, I do not recommend attempting transporting specimens onboard an airplane. In the majority of cases, it is easier and safer to send the specimens by courier.

Due to the fact that DOT defines small quantities as non-hazardous, these quantities are allowed in hand and checked baggage on domestic flights but must be declared to the airline staff before boarding. The final decision as to whether or not to accept these packages is made by the pilot of the aircraft being boarded, thus you may be denied permission to carry the package onboard at the last minute. Whether or not the package will be allowed onboard varies from flight to flight and from airline to airline. Some individuals have suggested simply pouring off the excess liquid preservative before flying but there is no guarantee that this will be acceptable and it has yet to be determined whether removing liquid alcohol from specimens and carrying them “dry” would negate the need to declare these as dangerous.

In 2013 specific regulations were put in place for carrying scientific research specimens as hand and checked baggage in the IATA manual. In Section 2.3 – Dangerous Goods Carried by Passengers and Crew, a Section 2.3.5.14 has been added that states:

2.3.0 General

2.3.0.1 Dangerous goods, including excepted packages of radioactive material, must not be carried by passengers or crew:

• as or in checked baggage;
• as or in carry-on baggage; or
• on their person;

except as noted in 2.3.2 to 2.3.5

2.3.5 Goods Acceptable without the Operator's Approval

2.3.5.14 Non-infectious specimens packed with small quantities of flammable liquids

In checked or carry-on baggage non-infectious specimens, such as specimens of mammals, birds, amphibians, reptiles, fish, insects and other invertebrates containing small quantities of flammable liquids provided that the requirements of Special Provision A180 are complied with.

However, it is important to note that TSA regulations in the US override any other regulations so in carry-on bags you will be limited to the 3.4oz (100ml) containers which must fit in a quart-sized zip lock bag. TSA Liquid Rules

Natural history specimens

In real-world collection scenarios, the common practice of wrapping specimens in cheesecloth or gauze moistened with alcohol and sealed in plastic would keep the material from being a dangerous good as long as no more than 30 mL of 70% ethanol was used in each individual package and the heat-sealed plastic bags are at least 0.2mm thick. Each package would need to be placed in secondary packaging material (usually another bag) sealed in the same way and with sufficient absorbent material (3M sorbent pad) and then placed in an approved box with cushioning material (packing peanuts). Most collections are moving away from vermiculite due to the potential for it to contain asbestos and the fact that it is so messy to deal with. 3M sorbent pads or similar can be cut to size and inserted very easily (and can potentially be re-used). I have found that purchasing variable size (multi-depth) boxes that can be cut down to the appropriate size (available from ULINE or other vendors) reduces the number of different sized boxes we need to keep on hand, potentially reduces shipping costs and allows you to more easily comply with drop test regulations (as only one sample box needs to be tested rather than each box if you are reusing boxes). It is recommended that old boxes not be re-used for shipping specimens, as they may have old labels that cause confusion at mailing facilities. All old labels must be defaced or removed before packing.

Specimens preserved in 3.7% formaldehyde can be shipped in regular mail both domestically and internationally without any dangerous goods requirements.

Tissues can be placed in cryovials or glass vials in less than 30 mL of 99% ethanol if the caps are secured with tape or Parafilm, and the vials placed in a secondary heat sealed plastic bag with absorbent material and packed similar to the above.

Although it is widely believed that reducing the concentration of alcohol below 24% renders specimens outside of the scope of dangerous goods regulations, from Tables 1 and 2 this is clearly not the case. Even at concentrations of 10%, both ethanol and isopropanol fall within the bounds of Packing Group III (flashpoints greater than 23°C and less than 60°C). The confusion stems from passages in the IATA regulations (Section 2.3) pertaining to beverage alcohol which states that “alcoholic beverages containing 24% or less alcohol by volume are not subject to any restrictions”. This regulation only pertains to beverage alcohol in retail packaging and cannot be used for natural history specimens.

It has also been suggested that fluid preserved specimens may be placed in water for shipment. Although this may put specimens outside of the scope of dangerous goods regulations, the possibility of damage to specimens from swelling (and subsequent shrinkage upon reinsertion into alcohol), cell wall rupture, mold, and bacterial growth will severely endanger the specimens, particularly if the shipment is delayed.

Problems and concerns

These above covers the majority of all natural history dangerous goods shipments but there are still some areas of concern or where problems still exist:

1. Large specimens that require more than 30 ml to adequately moisten the specimen for transport must be packaged as regular dangerous goods (not excepted/small quantities) and are subject to the more restrictive regulations, labeling and paperwork of such shipments.
2. Specimens may not be sent to countries that do not accept dangerous goods. This is particularly concerning if loaned specimens are unable to be sent back. At present, there is no solution to this problem.

We have been working on accumulating documentation and regulations for other international countries. Some are of particular concern including Brazil but Mark Sabaj (fish collections manager at ANSP) has produced a wonderful webpage explaining all the ins and outs of the process of Brazilian shipping. We would be happy to receive similar updates on other countries that are problematic - Australia, China, Russia, the EU, etc.

Source Material

Bentley, A. Shipping and Handling of Natural History Specimens in Dangerous Goods, 2008. Collection Forum 22(1-2), pp. 66-73. Society for the Preservation of Natural History Collections.

Conference Presentations & Training Modules

Neumann, Dirk. Legal Requirements. SPNHC 2017 Annual Meeting Shipping Workshop, Denver.
Neumann, Dirk. Veterinarian Law. SPNHC 2017 Annual Meeting Shipping Workshop, Denver.
Giere, Peter. CITES and Species Protection Legislation [European perspective]. SPNHC 2017 Annual Meeting Shipping Workshop, Denver.
Neumann, Dirk. IATA Dangerous Goods Regulations & IATA Training Module. SPNHC 2017 Annual Meeting Shipping Workshop, Denver.
Neumann, Dirk. Customs Law. SPNHC 2017 Annual Meeting Shipping Workshop, Denver.
Carson, Stephanie Permits (US Import/Export Permits). SPNHC 2017 Annual Meeting Shipping Workshop, Denver.
Neumann, Dirk. Packaging and Documentation. SPNHC 2017 Annual Meeting Shipping Workshop, Denver.

References

1. ↑ Title 49 CFR, Subtitle B, Chapter 1, Subchapter C: Hazardous materials regulations. US Department of Transportation (DOT).
2. ↑ USPS Publication 52: Hazardous, Restricted, and Perishable Mail. Part 3: Hazardous Materials. Pgs 15-60. July 1999.
3. ↑ IATA Dangerous Goods Regulations, 48th Edition. 2007. Section 2 - Limitations pgs 9-80. International Air Transport Association.