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The Materials OF Trade ( not “in Trade”) exception could be useful for employees of a private educational institution moving chemicals, but within limits. Only some hazard classes are covered, the size of packages is limited, packaging must be at least as good as the original packaging (if not the original) and must be secured against movement in transport. The aggregate gross weight of all materials of trade in one motor vehicle cannot exceed 200 kg.
But for employees of a public university moving regulated hazardous materials on university business, Materials of Trade is irrelevant since they are not engaged in commerce and thus are not covered by the DOT Haz Mat shipping regulations. Of course any public university choosing to move such materials would be well advised to comply with the regulations as much as reasonably possible. The alternative is risk of a substantial law suit and really bad publicity if the transport goes bad and people are hurt or substantial property damage occurs and can be attributed to “short cuts” used because the regulations did not apply.
Peter Zavon, CIH
Penfield, NY
PZAVON**At_Symbol_Here**Rochester.rr.com
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Russ Phifer
Sent: Wednesday, December 07, 2016 1:14 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Moving labs in University
I agree with Ed; the specific regulatory reference is the Materials in Trade Exception (49CFR 173.6). You do not need to hire a “licensed” company to transport hazardous materials from one of your facilities to another, or across campus. You do need to utilize DOT packaging if you are going on public roads, and need a hazardous materials bill of lading (available online or in office supply stores) to accompany the load.
This exemption also applies to field studies (stream sampling, for instance) and to Chem Week type chemistry demonstrations at shopping malls and other public places.
Hazardous waste transport is not allowed under this exception, but you can transport hazardous waste around your campus as long as you are crossing public roads but not going onto public roads.
Russ
Russ Phifer
WC Environmental, LLC
1085C Andrew Drive
West Chester, PA 19380
Fax 800-858-6273
Cell - 610-322-0657
rphifer**At_Symbol_Here**wcenvironmental.com
http://www.wcenvironmental.com
P Please consider your environmental responsibility before printing this e-mail or any other document
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Edward Movitz
Sent: Wednesday, December 07, 2016 12:38 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Moving labs in University
A government employee, transporting government owned material, from one government location to another government location, either on public roads or not, is not subject to any DOT regulations.
WVU employees can load a WVU truck with WVU chemicals (carefully) and drive to any other WVU campus.
DOT regulates transportation in commerce, and the government transportation of government materials as described above is not a commercial activity.
Ed
Edward M. Movitz
Research & Environmental Compliance Officer / FSO
The University of Mississippi
Laboratory Services
100 Health and Safety Building
P.O. Box 1848
University, MS 38677-1848
U.S.A.
O:+1-662-915-5433 | F: 662-915-5480
movitz**At_Symbol_Here**olemiss.edu | www.olemiss.edu | Laboratory Services Web Site
Please Consider the Environment before printing this Email.
Confidentiality Note: The information contained in this e-mail and/or document(s) attached is for the exclusive use of the individual named above and may contain confidential and privileged information. If you are not the intended recipient, please immediately delete this message and all copies of it from your system. You are hereby notified that you are strictly prohibited from reading, photocopying, distributing or otherwise using this e-mail or its contents in any way. If you have received this transmission in error, please notify the sender immediately.
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Barbara Foster <bfoster**At_Symbol_Here**WVU..EDU>
Sent: Wednesday, December 7, 2016 11:10 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Moving labs in University
You don’t mention the specifics on distance and/or routes, but you have to follow all DOT regs when transporting hazardous materials on roadways. You will have to hire a licensed company to move hazardous materials across campus.
Barbara L. Foster
College Safety Officer
Eberly College of Arts and Sciences
West Virginia University
DCHAS Fellow - American Chemical Society
304-293-2729 (desk)
304-276-0099 (mobile)
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Fu, Zhen
Sent: Wednesday, December 07, 2016 10:01 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] Moving labs in University
Hi all,
Could you please share the policy or procedures on moving batch of chemicals within university from one building to the other? What EHS’s role on this matter?
Thank you,
Zhen
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--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org
--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org
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