Marjorie - your staff is allowed to do the packing and moving under the US DOT Materials of Trade exemption. However- all hazardous materials must be packed according to DOT specifications (no cardboard boxes in the back of the minivan), and the proper paperwork must accompany each shipment. That means a hazardous materials bill of lading, with proper shipping name, hazard class, packing group, and DOT number.
You might find it advantageous to at least have a contractor assist with the move since there is still a lot that can go wrong. If you have qualified, trained staff to establish the right hazard class then you might be able to do it yourselves, I suppose. I'd recommend spending some time with 49CFR 172.101 (Column 8, in particular), to make sure everything is packed according to spec. You could most likely use fiber drums or boxes to pack most of the chemicals, commingling by hazard class.
Russ
Russ Phifer
WC Environmental, LLC
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West Chester, PA 19380
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Cell - 610-322-0657
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From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of drsamples**At_Symbol_Here**COMCAST.NET
Sent: Friday, April 13, 2012 7:40 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Two Questions
I have a related question to the chemical transport question. A new science building at a rural college in California is now being finished, so they will have to pack and transport all of the chemicals from the old building to the new building. These would be chemicals that are typical for general first-year inorganic chemistry. Are the faculty and lab tech allowed to do the packing and moving of chemicals themselves or are they required to hire outside specialists? Are there any rules or prudent guidelines to follow in moving and supervising the move?
Thank you,
Marjorie Samples
Los Rios College District
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