Does your university work require the transport of hazardous materials in private or university owned motor vehicles?
If so, the Department of Transportation (DOT) regulations apply. What to know before you go:
A hazardous material is defined as a substance or material that has been determined by the DOT title 49 of the Code of Federal Regulations (CFR) to be capable of posing an unreasonable risk to health, safety, and property when in transport. Materials that are hazardous to the environment (i.e., hazardous substance, hazardous wastes, and marine pollutants) are also regulated. Hazardous materials include but are not limited to:
For a general understanding of hazardous material transportation regulations and how to apply them, DRS developed a training, Awareness Training for the Transport of Hazardous Materials.
For certain hazardous materials called materials of trade in limited amounts, there are exemptions to the full requirements that normally apply (see 49.CFR 173.6). Most university transport falls under this exemption, for example, when a university worker must transport a hazardous material, other than a hazardous waste, on a motor vehicle to support job duties or for the operation and maintenance of equipment.
Many commonly transported materials fall under the exemption such as gasoline, diesel fuel, ethanol, formalin solutions, acid solutions, and dry ice. The amounts are limited to 30L/30 kg (8 gallons/66 pounds). The table below outlines the hazard class and allowable amounts to be transported under the Material of Trade exemption. For chemicals not specifically listed in the table, check section 14 of the Safety Data Sheet (SDS) to identify the hazard class and packing group. If you don’t have an SDS or have questions, contact DRS.
Hazard Class |
|
Class 1 – Explosives | Cannot be transported! |
Class 2 – Gases | |
| In a cylinder with gross weight ≤ 100 kg (220 lbs) In a dewar flask ≤ 25.3 psi Ex: cryogenic liquids (ethylene; hydrogen; methane); ethane; compressed (hydrogen; methane; deuterium); acetylene, dissolved; petroleum gases, liquefied (butane; butylene) |
| In a cylinder with gross weight ≤ 100 kg (220 lbs) In a dewar flask ≤ 25.3 psi Ex: cryogenic liquids (argon; helium; nitrogen); compressed gases (air; argon; helium; nitrogen; oxygen); carbon dioxide (liquified, compressed) |
| Cannot be transported! Ex: carbon monoxide; fluorine; nitric oxide |
Class 3 – Flammable Liquids | Packing Group I: 0.5 kg (1 lb) or 0.5 L (1 pt)
Packing Group II, III, or no packing group: 30 kg (66 lbs) or 30 L (8 gal)
|
Class 4 – Other Flammable Substances | |
| Packing Group I: 0.5 kg (1 lb) or 0.5 L (1 pt)
Packing Group II, III, or no packing group: 30 kg (66 lbs) or 30 L (8 gal)
|
| Cannot be transported! |
| Packing Group II, III, or no packing group: 30 mL (1 ounce)
|
Class 5 – Oxidizing Substances & Organic Peroxides |
|
| Packing Group I: 0.5 kg (1 lb) or 0.5 L (1 pt)
Packing Group II, III, or no packing group: 30 kg (66 lbs) or 30 L (8 gal)
|
| Packing Group I: 0.5 kg (1 lb) or 0.5 L (1 pt) Packing Group II, III, or no packing group: 30 kg (66 lbs) or 30 L (8 gal) |
Class 6 – Poisonous (Toxic) and Infectious Substances | |
| Packing Group I: 0.5 kg (1 lb) or 0.5 L (1 pt). Except: Poisonous by inhalation cannot be transported (see SDS section 14). Packing Group II, III, or no packing group: 30 kg (66 lbs) or 30 L (8 gal)
|
Category A: Cannot be transported! Category B : Biological material and regulated medical waste, including sharps, is potentially infectious. Requires additional training, contact DRS Unregulated and Exempt: See Classification Guide | |
Class 7 – Radioactive Materials | Cannot be transported! |
Class 8 - Corrosives | Packing Group I: 0.5 kg (1 lb) or 0.5 L (1 pt)
Packing Group II, III, or no packing group: 30 kg (66 lbs) or 30 L (8 gal)
|
Class 9 – Miscellaneous Hazardous Materials | Packing Group I: 0.5 kg (1 lb) or 0.5 L (1 pt) Packing Group II, III, or no packing group: 30 kg (66 lbs) or 30 L (8 gal)
Dilute mixtures (≤2%) of a Class 9 material: 1500 L (400 gal) |
The aggregate gross weight of all materials of trade on a motor vehicle must not exceed 200 kg (440 pounds), except for dilute mixtures of class 9 material.
For any transport of hazardous material in excess of the amounts listed in the table or hazardous materials listed as “cannot be transported”, the full requirements of 49 CFR 173 apply, including adequate training of those involved with the transport (packing, loading, driving).
Hazardous Chemicals
Transport materials in the manufacturer’s original container if possible; or a container of equal or greater strength and integrity. Containers must be leak-tight and securely closed. Tape lids so that they do not unscrew during transport.
Place containers in secondary containment sufficient to hold spilled material. Include sufficient absorbent pads or material to absorb all liquid. Use separate secondary containers for incompatible chemicals.
When filling containers with liquids, leave sufficient head space in the container for the liquid to expand. Consider the potential for temperature rise during transport to prevent pressure build-up,
Gasoline must be transported in approved containers only.
Secure containers in the vehicle against shifting by using straps to directly secure to the vehicle. Protect against damage by placing them in boxes, carts, bins, etc. with padding. If possible, transport hazardous material in the bed of a pick-up truck or inside the trunk and not in the passenger cab. This is especially important for volatile material that may evaporate during transport if spilled.
Consider the potential for vehicle contamination. For example, gasoline spilled on vehicle carpet is very difficult to clean up and can emit intense odor for long periods of time.
Unregulated and Exempt Biological Materials
See Biological Material Transport.
Compressed Gas Cylinders
Cylinders must be transported with the protective valve cap secured in place. Cylinders must be secured to tie down points in the vehicle using sturdy straps such as ratchet-style-tie down straps or similar. Bungee cords or seatbelts are not adequate.
Ideally, cylinders should be transported in the bed of a pick-up truck, not inside the passenger cab as a leak could lead to oxygen depletion.
Cryogens and dry ice
Due to the slow but constant evaporation, cryogens and dry ice cannot be transported in sealed containers without pressure relief devices. As the evaporation could displace oxygen, asphyxiation is a real hazard inside a vehicle cab. Whenever possible, transport cryogens and dry ice in the bed of a pick-up truck. Small amounts (< 1L) may be transported inside the vehicle cab for short travel distances with a window open.
Label all containers with the common name of the material that is understood by the public. Include the letters “RQ” if it contains a reportable quantity of a hazardous substance (see section 14 of the SDS if your chemical is not listed specifically in the table).
If reusing packaging received from hazardous materials shipment, make sure it is free of contamination. Check labels and hazardous material markings and remove them if they do not match the hazards of the materials inside.
A bulk packaging (container size > 450 L (119 gallons) containing a diluted mixture of a Class 9 material must be marked on two opposing sides with the four-digit identification number of the material. The identification number must be displayed on placards, orange panels or, alternatively, a white square-on-point configuration having the same outside dimensions as a placard (at least 273 mm (10.8 inches) on a side), in the manner specified in §172.332 (b) and (c) of this subchapter.
The operator of a motor vehicle transporting a material of trade must be informed of the presence of the hazardous material and if it is a reportable quantity.
Bring PPE (gloves and eye protection) and sufficient material to clean up spills of the transported materials. See Preparing for potential spills for information on spill-clean up. You should not wear PPE when transporting material through public spaces.
Be aware that containers may have shifted during transport and that liquids may have built-up pressure. Wear appropriate PPE and open containers away from your body.