First, we all make mistakes. It may be that one was made. Second, three groups -- US DOT, International Maritime Organization, International Civil Aviation Organization -- all have definitions of hazardous materials. They overlap significantly but there are differences. If a material is "hazardous" it must be packaged, marked, labeled, and in all respects in proper condition for transportation and certified or declared as such. For most situations, the International Air Transport Association (IATA) regulations may be substituted for the International Civil Aviation Organization (ICAO) regulations. Third, there are three ways a hazardous material may be packaged: a limited quantity, a non-bulk quantity, or a bulk quantity. Within limited quantities, there are exempt quantities and limited quantities (a rather redundant use of the term in the regulations). When shipping exempt and limited quantities, because of the smaller size of the inner packaging or receptacle and therefore a smaller hazard, less secure packaging may be used. I cannot imagine a situation where, when opening a shipping package, the inner receptacle may be breached accidentally. Depending on the mode of transportation (DOT, IMO, IATA) and the specific packaging requirements, the proper shipping name and identification number of the hazardous material may not be required on the outer shipping package. "Required" and "a good idea" are not necessarily the same things. Just because it is not required does not mean it is not a good idea to fully and accurately describe the nature of the hazardous material in the inner package or receptacle. Fourth, when a person is exposed to an unknown hazard created by perhaps inappropriate or unauthorized packaging, that is probably the operational definition of a bad situation. Allowing bad situations to continue is always a bad thing. Stick to your guns. Be good, do good, and be safe. George Walton Reactives Management Corporation 1025 Executive Blvd., Suite 101 Chesapeake, VA 23320 Office: 757-436-1033 Fax: 757-548-2808 -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of stan arango Sent: Friday, May 20, 2011 6:39 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: [DCHAS-L] Acceptable Methods For Shipping Chemicals question for posting I wanted to get some feedback on a situation that I encountered recently. I was told by my supervisor that the e-mail I sent to a vendor was inappropriate and unprofessional (scroll to the bottom of the screen). According to my supervisor if the chemical was really toxic the vendor would not have chosen to ship their product in a plastic bag. It seems to me that shipping any type of chemical in a plastic bag is a bad idea. Here is an excerpt from the MSDS that was e-mailed to me: Section 6 - Accidental Release Measures General Information: Use proper personal protective equipment as indicated in Section 8. Spills/Leaks:ELIMINATE all ignition sources. Do not touch damaged containers or spilled material unless wearing appropriate protective clothing. Stop leak if you can do it without risk. Absorb or cover with dry earth, sand or other non-combustible material and transfer to containers. DO NOT GET WATER INSIDE CONTAINERS. Section 7 - Handling and Storage Handling: Avoid breathing dust, vapor, mist, or gas. Avoid contact with skin and eyes. Avoid ingestion and inhalation. Storage: Store in a cool, dry place. Store in a tightly closed container. Section 8 - Exposure Controls, Personal Protection Engineering Controls: Facilities storing or utilizing this material should be equipped with an eyewash facility and a safety shower. Use adequate ventilation to keep airborne concentrations low. I was the CHO for my company for three years and completed the ACS three day CHO course back in 2007. After it became apparent to me that Management was not genuinely concerned with creating a safe work environment I have since resigned as the CHO. I still function as the Lab Manager for the medicinal chemistry department and one of my responsibilities is receiving incoming chemicals. Part of my frustration comes from the scientist's perception that because they are knowledgeable about chemicals they are knowledgable about chemical safety. In my opinion there is a big difference between the two. Interested to hear what other non-scientists that are functioning as a safety officer have to say. Also, I am not a doctor I just play one on TV. :-) Thanks, Stan Arango ------------------------------------------------------------------------- ------- From: Sent: Monday, May 16, 2011 12:45 AM To: Stan Arango Cc: Subject: Reply: Fw: Fw: Unsafe shipment of chemical Hi Dr Stan Arango, Thank you very much for your info. Firstly, Please accept my sincerest apology for shipping method and packaging. For Clearance purpose, our shipping agent ship the compound by other sample's name, and we are requested print the CAS number and our Catalog number on the Label, and it is allowed send the MSDS with the compound together. Please see attached MSDS. Regarding packing, sorry again for the inconvenience. I have forward it to our Logistics Dept, and we will improve it in future, I can assure that the similar things could not occur again in the future. Please let me know if you have any other questions or conerns. Sorry once again for any inconvenience! Yours faithfully, =E6=9D=A8=E6=B0=B8=E5=AE=81 ******************************************************** > To Whom It May Concern, > > Your shipping method for your product catalog # 60-61118 is unacceptable. During the process of opening the aluminum foil envelope that the chemical came in the plastic bag containing the chemical was inadvertently also opened (see attch'd photos). This is an especially dangerous shipping practice because your product did not include a chemical name or MSDS so I do not know what type of chemical I have been exposed too. Thanks in advance for your speedy reply concerning this matter. > > Stan Arango > Lab Manager, Associate
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