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Regulatory Compliance: Shipping Dangerous Goods
December 5, 2006, Volume 53, No. 14

The Federal Aviation Administration (FAA) conducted an inspection at the University and UPHS in November to review the training and shipping records of faculty and staff that have recently shipped dangerous goods.

Shipping dangerous goods/hazardous materials (chemicals, radioactive materials, infectious substances, biological materials and dry ice) within and outside of the United States is subject to strict government regulations and airline industry and ground carriers’ requirements. The U.S. Department of Transportation (DOT) and the International Air Transport Association (IATA) established strict standards for these shipments in terms of training, proper paperwork, labels, placards and packaging. Stiff fines and penalties, up to $32,500 per instance, can be imposed against companies or individuals who fail to comply with the applicable regulations. Shipping regulations state that it is the responsibility of the shipper to ensure that all of the regulatory requirements for shipping a package are met.

During the inspection the FAA identified a number of apparent deficiencies:

• The required training was not completed or the training had expired. Training is good for two years.

• A copy of the training certificate was not available.

• A copy of the “Shippers Declaration for Dangerous Goods” was not available. These documents must be kept for a minimum of two years.

• “Shippers Declarations for Dangerous Goods” were incorrectly completed.

• In some cases, improper emergency phone numbers were used. A 24-hour phone number for emergency response must be included on each Shipper’s Declaration. In order to comply with this requirement, the University and UPHS require the use of CHEMTREC 1-800-424-9300, as our emergency response contact number. Penn has an account with CHEMTREC for this service. There is no fee for individual shippers.

The Office of Environmental Health and Radiation Safety (EHRS) provides training and assistance to those who plan to ship dangerous goods. Training is required for anyone that participates in the shipping process. This includes packing, marking, labeling and/or completion of documentation. A shipping manual and an online training program are provided at the EHRS website www.ehrs.upenn.edu.

In order to ensure compliance and accuracy, the “Shippers Declaration for Dangerous Goods” that accompanies each package must be faxed to EHRS at (215) 898-0767 before the shipment leaves the University.

Shipping regulations must be followed. Both personal and institutional penalties can be imposed. Each individual who fails to follow the regulations can be fined and/or jailed. The University can also be fined.

For more information, please contact Sue Souder, EHRS senior biosafety officer at (215) 746-6641 or visit our website www.ehrs.upenn.edu/resources/shippinghazmats/default.html.

—Office of Environmental Health and Radiation Safety

Almanac - December 5, 2006, Volume 53, No. 14