Hazardous Materials Transportation
The U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR) 49 CFR Parts 171-180 apply to all transportation of hazardous materials by aircraft, railcar, vessel, and highway in the United States. In conjunction with the HMR, international and U.S. domestic air shipments must be prepared according to the International Civil Aviation Organization (ICAO) as published in the International Air Transport Association (IATA) Dangerous Goods Regulations. Combined, these regulations:
- Require training for anyone who prepares, offers, or receives regulated materials for shipment
- Outline responsibilities for anyone involved in activities related to the shipment of hazardous materials (domestic) and dangerous goods (international)
- Define nine hazard classes and divisions when applicable
- Specify proper classification, packaging, and labeling requirements and documentation of all shipments
- Provide procedures for security assessment
- Establish penalties for non-compliance
The purpose of this program is to provide IU employees involved in activities related to hazardous materials transportation with comprehensive guidance for regulatory compliance. Compliance with DOT regulations is a requirement for any person who offers a hazardous material for shipment.Non-compliance with the federal HMR can result in civil or even criminal penalties for the University and the individual(s) responsible for the violation.
This Program applies to all Indiana University employees who ship or receive packages containing materials regulated for transport and to all employees who transport hazardous materials.
- University Environmental Health and Safety (IUEHS) is responsible for
Developing and implementing the Hazardous Materials Transportation Program
Serving as a technical resource in support of this Program, including training courses or referrals to vendor training as needed
Maintaining required training records
Maintaining the Hazardous Materials Security Plan for each campus, if required.
- Departments are responsible for
Ensuring compliance with Program elements among department employees
Reporting non-compliance to their campus IUEHS immediately
Identifying HazMat employees and ensuring they are trained as specified in Section 4.1
Arranging for training if choosing a source outside of IUEHS
Providing training records for any outside training to IUEHS for your respective campus
Identifying and obtaining all necessary shipping supplies
- Employees are responsible for
Completing all required training for all applicable hazardous materials functions
Complying with all aspects of this Program
Identifying HazMat Employees
Departments must identify and train employees who meet the regulatory definition of a “HazMat Employee”. A HazMat employee is anyone who performs the following job functions for hazardous materials in commerce:
- Prepares hazardous materials for shipment (packs, marks, labels shipping containers)
- Offers hazardous materials for shipment (fills out and/or signs shipping papers)
- Handles hazardous materials packages (accept incoming packages) and/or
- Transports hazardous materials.
University employees who perform any of the above functions for packages that are shipped or delivered by non-IU employees, must complete online Hazardous Materials Transportation Training. Therefore, if one employee packages a hazardous material, and another employee fills out the shipping paper (e.g. airway bill), both employees require training.
University employees who only receive packages of hazardous materials from IU employees, like IU Mail Room or receiving dock personnel, must complete online Hazardous Materials Transportation Training - for Receiving Only.
Training offered by other public or private sources must meet the training requirements of this Program. Records of training by all outside sources must be provided to IUEHS to ensure proper content and documentation. Specific information on required training elements can be found in Section 4 of this Program.
Alternatively, trained IUEHS professionals at the respective IU campus may be able to serve as a technical resource for employees with infrequent or one-time shipping needs.
Identifying Harzardous Materials
Employees must be able to identify hazardous materials they are shipping or receiving. Hazardous materials can be identified in several ways, including:
- Shipping papers for incoming packages will indicate if it contains a hazardous material
- Safety Data Sheet (SDS) Section 14: Transportation Information
- Package markings and labels
Packages that contain hazardous materials are marked with a diamond-shaped DOT Hazard Class label or marked ORM-D (regulated consumer commodity). DOT has assigned nine general hazard classes as follows:
|2||Gases – Flammable/Non-Flammable/Toxic|
|4||Flammable Solids, Pyrophoric/Dangerous When Wet Materials|
|5||Oxidizers and Organic Peroxides|
|6||Poisons and Infectious Materials|
|8||Corrosive Liquids and Solids|
Some hazard classes are broken further down into divisions. Common examples of hazardous materials at IU include: toxic, corrosive or flammable laboratory reagents, solvents, compressed gas cylinders, and biological and radioactive materials. There are some exceptions to the regulations, which include materials of trade (MOT), materials transported within the University that are not in commerce, and very small quantities of certain hazardous materials.
Due to the nature of University operations, and because DOT only regulates hazardous materials that are shipped in commerce, there are many regulatory exceptions under which hazardous materials can be transported on campus. However, many activities (HazMat Employee functions) still require safe, compliant procedures and training. This section outlines the specific requirements and procedures for activities covered by this Program. Procedures for radioactive materials are covered in the IU Radiation Safety Manual for each campus.
- Receiving, Picking Up, and Delivering Hazardous Materials
Receiving Materials from a Commercial Shipper
Any IU employee who signs for a hazardous materials package or shipment must be trained as a HazMat Employee. If no trained employee is available, a package cannot be accepted until a trained employee or IUEHS representative is contacted, and arrives to sign for the material. This includes packages containing dry ice.
Packages must be opened by the addressee only.
Package must be inspected for visible signs of damage. If damage, leaks or strong odors are noted, the package must be rejected back to the carrier. It is the transporter’s responsibility to return it to address leaks and return the package to the shipper. If a problem arises or is noticed after acceptance, isolate the package from building occupants in ventilated area if possible, and follow your campus emergency procedures for a chemical spill.
Paperwork for acceptable packages must be verified as accurate and signed.
Special handling requirements (e.g. keep cold) must be noted. Handle the package accordingly.
Hazardous materials must not be left unattended, stored outside, or in areas where they could become damaged, misplaced, or stolen. Do not store packages of hazardous materials in areas where food is being stored or served, such as break rooms.
Package addressee must be contacted immediately if they are required to pick up the package from a separate receiving location. See below if you are delivering the package to the addressee.
If you receive a suspicious package, or a package becomes missing or stolen, report the problem to University Police at your respective campus.
Picking up Materials from a Campus Receiving Facility or Stock Room
Intra-building transport takes place within the same building, or an adjacent, connected building without the need to go outside with the hazardous material.
Any IU employee that picks up a hazardous material for intra-building transport must have either Hazard Communication Training or Laboratory Safety Training and be familiar with spill reporting and response procedures.
Packages should be checked to verify the recipient, and that the shipment is accurate and complete. Do not open hazardous materials shipping packages until you reach your destination.
IUEHS recommends using a cart with a secondary containment lip for transporting any hazardous materials through hallways. However, you may hand-carry up to two (total) containers in safety totes only.
A freight elevator must be used if available for moving hazardous materials within buildings. Stairs must be avoided when feasible.
Inter-Building Pick-up by Vehicle
- Vehicle transport of hazardous materials by IU employees from one IU building to another, must be trained as a HazMat Employee per this document. Training is available online by following the link at protect.iu.edu. Contact IUEHS at your respective campus if you have additional questions regarding authorization and training options.
- Hazardous materials transport in personal vehicles is prohibited under any circumstance. Only IU vehicles (owned, leased, or rented) are to be used for transporting hazardous materials.
- If you are picking up a material from the receiving facility or mailroom, you must leave it in its original shipping packaging until you get it to its final location.
- If you are picking up material(s) from a stock room, you must use a cushioned box or cooler, Styrofoam® bottle holders, or equal method for holding the containers and preventing them from tipping or rattling together while you travel between buildings. If materials are unpackaged, you must segregate incompatible materials according to hazard (seeAppendix B) and box or containerize them separately so that no mixing will occur if they break or spill in transit.
- Hazardous materials must not be transported in the passenger compartment of any vehicle. All hazardous materials transport must be confined to cargo areas or trunks of vehicles.
- Transport of hazardous materials is limited to 15 gallons of liquid and/or 50 pounds of solids in an IU vehicle at any one time unless otherwise approved by IUEHS.
- Gas cylinders are not to be transported by vehicle unless they can be secured and kept upright inside the vehicle as is required for all cylinders.
Delivering Materials to IU Locations
Intra-building transport takes place within the same building, or between buildings connected by tunnels or other means that eliminate the need to go outside with the hazardous material.
Intra-building delivery of hazardous materials requires IU employees to have either Hazard Communication Training or Laboratory Safety Training, and be familiar with spill reporting and response procedures.
Packages for delivery must be left in the original shipping container, and must be opened only by the addressee.
Employees who deliver hazardous waste to IUEHS (IU Bloomington campus only), must review relevant portions of the IU Waste Management Guide at least annually and complete the Waste Management Training for Laboratory Employees or Waste Management Training for Non-Laboratory Employees annually.
Materials that are unpackaged must be delivered using a box or tub with absorbent, cushioning material. Take care to stabilize glass containers so that they do not rattle or break in transit.
Inter-Building by Cart Delivery
- Any IU employee that prepares or delivers a hazardous material delivery to an IU facility that is not within the same building (intra-building), but is accessible via cart by gently sloped paved surfaces, with available crosswalks and low pedestrian and vehicle traffic must follow the procedures for intra-building deliveries above.
Inter-Building Delivery by Vehicle
Packaged material must remain in the original shipping package until it is delivered to its final location.
Unpackaged material(s) for delivery by vehicle must be packed into a cushioned box or cooler, compartmentalized Styrofoam® block, or equal method for holding containers, and preventing them from tipping or rattling together. Segregate and box or containerize materials according to hazard (see Appendix B).
Transport of hazardous materials is limited to 15 gallons of liquid and or 50 pounds of solids in an IU vehicle at any one time.
An SDS must be provided to the delivery driver for packages that do not clearly indicate the contents on the outer container.
- All un-boxed materials must be in sturdy, flat-bottomed containers that will not tip in transit and properly secured while the vehicle is in motion.
- Gas cylinders are not to be transported by unless they can be secured and kept upright inside the vehicle as is required for all cylinders.
- Transporting Hazardous Materials to Work or Research Sites
Any IU employee that moves hazardous materials from their shop, storage, or laboratory location to a temporary work or research location within the confines of the same campus must have either Hazard Communication Training or Laboratory Safety Training.
- Hazardous materials trasnported in pernal vehicles is PROHIBITED under any circumstance. Only IU vehicles (owned, leased, or rented) are to be used for transporting hazardous materials.
All materials not in boxes, must be in sturdy, flat-bottomed containers that will not tip in transit and must be properly secured, if applicable, while the vehicle is in motion.
Any IU employee that moves hazardous materials from their shop, storage, or laboratory location to a temporary work or research location not located on campus must be trained as a HazMat Employee. Transportation of portable assay kits for field work does not require training as a Hazmat employee, but does require Laboratory Safety Training. Users of these kits must read and follow any directions and safety information provided by manufacturers and are advised to contact the manufacturer or IUEHS if they have any safety related questions.
All materials not in boxes, must be in sturdy, flat-bottomed containers that will not tip in transit and must be properly secured, if applicable, while the vehicle is in motion.
- Shipping Hazardous Materials by Commercial Carriers
- All shipments of hazardous materials to non-IU locations must be done by licensed commercial carriers subject to the hazardous materials regulatory requirements of 49 CFR Parts 171-180.
- All IU employees preparing hazardous materials for shipment by commercial carrier or signing hazardous materials shipping paperwork must be trained as a HazMat Employee. Depending on the level of hazard and quantity of material to be shipped, additional requirements may apply including special packaging supplies. IUEHS may provide carrier recommendations, packaging guidance, training, and/or signatures on paperwork if necessary. Contact IUEHS as much in advance of the foreseeable shipping date as possible for assistance.
- Hazardous materials shipments by air have more restrictions than ground shipments. They should be avoided when feasible. IUEHS may assist as a technical consultant for air shipments to the extent possible given proper notification. Depending on the type and quantity of material you are shipping, special packaging requirements may require you to contract directly with a vendor that specializes in turnkey hazardous materials shipping.
Biological materials are a common hazardous material shipped and received at IU. Any employee who performs any HazMat function must be trained, depending on the type of material and functions performed. The following requirements are specific to DOT hazard class 6.2, Infectious Substances and Biological Materials.
- In addition to the general requirements above, all IU employees who receive, package or ship biological materials must complete training.
- Employees with functions limited to receiving or signing airway bills must be familiar with the hazards of the material, security measures, and spill response procedures. IU Hazardous Materials Transportation training is available online.
- For IU employees who perform more advanced functions related to shipping biological materials, such as identifying the material, selecting packaging, packing the shipping container, etc., the IU Shipment of Biological Materials training course is available online through E Training. Limited classroom sessions may be available. Contact your campus IUEHS for details.
- Note: This training includes shipping dry ice, so additional training for dry ice is not needed.
- A record of equivalent training may substitute for the above IU trainings. Documentation must be filed with IUEHS, and equivalency will be determined based on a review of the training content. See the Training section of this document for more information on training
- All IU employees who prepare packages for shipment with dry ice must follow IUEHS guidance.
All Other Hazardous Materials
- In addition to the transportation requirements of 49 CFR Parts 171-180, hazardous waste shipments are subject to the regulatory requirements of 40 CFR Parts 262-264. Because IUEHS needs to monitor these shipments closely, only IUEHS or their specifically authorized designees are allowed to sign the shipping paperwork for hazardous waste shipments.
- IUEHS must be notified of any project that will generate hazardous waste, and must approve all disposal facilities that will receive hazardous waste from IU.
If the need arises to ship any other type of hazardous material via commercial carrier, contact IUEHS at your respective campus for assistance.
- Chemical Moves to IU Locations
The IU Hazardous Materials Move Guide can be found in Appendix B of this document.
Hazardous Materials Security Plan
In 2003, DOT created a program that requires certain shippers and transporters to create security plans designed to limit access to hazardous materials that could be utilized in acts of malfeasance.
IUEHS will assess the applicability of the security plan requirement at each campus. When applicable, IUEHS will develop and maintain the Plan, and will also make security plan training available to affected employees.
Training and Recordkeeping
Initial training must be provided within 90 days of employment, or a change in job function(s) involving hazardous materials. Until trained, an employee may not perform HazMat shipping or receiving duties. Refresher training is required every two years.
The scope of training that employees receive depends on job function(s) and hazardous material(s) they handle. Regulation 49 CFR Part 172 Subpart H and Subpart I detail the types of training that must be included:
- General Awareness/Familiarization - Provide familiarity with the requirements of the regulations and to enable the employee to recognize and identify hazardous materials.
- Function-Specific - Provide training on the requirements of the regulations related to the employee's job functions.
- Safety - Provide information on hazards and instruction on safe handling, emergency response procedures and accident prevention.
- Security Awareness - Provide a general understanding of the security risks associated with hazardous materials transportation and methods to enhance transportation security, including how to recognize and respond to possible security threats.
Additionally, if a DOT Hazardous Materials Security Plan is required for the campus, training must also include:
- Comprehensive Security Training - Provide each HazMat Employee training on the Hazardous Materials Security Plan and its implementation. Security training must include University security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and the organizational security structure.
Training is implemented through various formats including in-person classroom, online, and on-the-job. Training may be performed by IUEHS for the respective campus, or by other public or private sources.
IUEHS offers Hazardous Materials Transportation Training online.
All trained employees will be required to demonstrate comprehension through testing. In order to demonstrate adequate comprehension, employees must score at least 80 percent on the training quiz. Employees who score less than 80% must re-take the training and test until the passing score is attained.
A training record must be created for each HazMat Employee for the current 2 year period. It must be retained for as long as that employee is employed by the University, and for a period of 90 days after separation from IU. Records of training by all sources must be communicated to UEHS to ensure proper documentation. The record must include:
The employee’s name
The most recent training date
A description, copy, or location of the training materials used to meet the training requirements
The name and address of the person providing the training
Certification that the employee has been trained and tested as required
Individuals who ship a hazardous materials package must retain a hard copy or electronic image of the shipping papers for two years. Each shipping paper copy must include the date of acceptance by the initial carrier. The copy must be accessible and available, upon request by a regulatory inspector.
- Appendix A: Glossary
Dangerous good - The international term for a substance or material capable of posing a risk to health, safety, property, or environment; that meets the criteria of one or more of the nine United Nations (UN) hazard classes; and, where applicable, meets the criteria for one of three UN Packing Groups according to the provisions of the Dangerous Goods Regulations (DGR) Section 3. The nine classes relate to the type of hazard whereas the packing group relates to the applicable degree of danger within the class. The international term for hazardous material.
DOT - Department of Transportation
Hazard Class - A group of hazardous materials that share similar dangerous characteristics, as defined by the DOT and UN.
Hazardous Material - a substance or material which has been determined by the U.S. Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated. The term includes items such as samples, reagent chemicals, and commercial products (dry ice, alcohol, acetone, formalin, etc.). Synonymous with dangerous good.
HazMat employer - Uses one or more HazMat employees (full-time, part-time, temporary or self-employed) to:
Transport hazardous materials in commerce
Cause hazardous materials to be transported or shipped in commerce or
Design, manufacture, fabricate, inspect, mark, maintain, recondition, repair or test a package, container, or packaging component that is represented, marked, certified, or sold by that person as qualified for use in transporting hazardous materials in commerce
HazMat employee - A person who is employed (full-time, part-time, temporary or self-employed) by a HazMat employer and who directly affects hazardous materials transportation safety by performing the following functions:
Loads, unloads, or handles HazMat
Tests, reconditions, repairs, modifies, marks, or otherwise represents packaging as qualified for use in the transportation of HazMat
Prepares HazMat for transportation
Responsible for safety of transporting HazMat
Operates a vehicle used to transport HazMat.
IATA - International Air Transport Association
Materials of Trade (MOT) - Hazardous materials, other than waste, that are carried on a motor vehicle to:
Protect the health and safety of the motor vehicle operator or passengers, such as insect repellant or a fire extinguisher
Support the operation or maintenance of a motor vehicle (including its auxiliary equipment), such as a spare battery or gasoline or
Directly support a principal business of a private motor carrier (including vehicles operated by a rail carrier) that is other than transportation by motor vehicle – for example, landscaping, pest control, painting, plumbing, or welding services.
Shipping Paper - a document which accompanies a hazardous material shipment that must be retained for two years as required by the DOT.
- Appendix B: Indiana University Hazardous Materials Move Guide
- Click here for more information.
New Document: April, 2015
Revised: October, 2017