SAFE PRACTICE Shipping Hazardous Materials GEORGE HUTCHESON, INDUSTRIAL HYGIENIST, JOHN DEERE FOUNDRY, WATERLOO, IOWA “I
f it fi ts, it ships,” is the catch- phrase of the U.S. Postal Service. If that also describes your ship-
ping department, you could be in for a major event. Typically, metalcasting facilities aren’t known as hazardous materials shippers. Still, those shipping regulations apply in many ways. Containers that haven’t been
cleaned have the same shipping requirements as full containers. If the container has been cleaned, then all marks and labels have to be removed because over-labeling is a violation. Improperly carrying a hazardous material, such as solvent-based paint, triggers regulatory requirements for training, classifi cation, packaging, marking and labeling unless the mate- rial qualifi es for one of the excep- tions such as the Material of Trade Exception. Spare lithium batteries are prohibited in checked luggage, includ- ing gate-checked luggage. Even small quantities of core resin samples can require packaging and documentation. Don’t think small shipments get
small fi nes. In 2010, the Federal Aviation Administration proposed small package penalties ranging from $54,000 to $91,000.
Who Sets the Rules? Hazardous materials shipping is
regulated by the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA). The regulations are in Title 49 of the Code of Federal Regulations, Parts 100 through 180, commonly known as the Hazardous Materials Regula- tions. To make matters more compli- cated, the HMR recognizes two sets of alternative regulations. T e International Maritime Orga-
nization has regulations for shipping dangerous goods by an ocean-going vessel in the “International Maritime Dangerous Goods” code. T e United Nations International Civil Aviation Organization’s “Technical Instructions for the Safe Transport of Dangerous Goods by Air” tell how to ship
Class 4 Flammable Solids Class 5 Oxidizers/Organic Peroxides Class 6 Toxic/Infectious Substances
hazardous materials by air. Individual airlines and other countries have ad- ditional regulations, listed in the In- ternational Air Transport Association’s “Dangerous Goods Regulations.”
What Do I Need To Do?
T e fi rst step is to see if you are shipping any regulated material. T e MSDS for chemical products is a good place to start, but be sure to verify the transportation information because some are out-of-date, some are just wrong, and some won’t list transportation information because it’s not required. T e hazard classes are shown in
Fig. 1. If you are shipping any of these materials you are probably subject to the regulations. T ese classes are not
Class 1 Explosives
all inclusive because the regulations cover “any material that could be dan- gerous in transportation.” Equipment with stored pressure or mechanical energy may be. Magnetic devices can be regulated for air shipment. If you are shipping regulated ma-
terials you need to develop a program that ensures that you are in compliance in these areas: training, packaging, marks/labels, documentation, placard- ing, separation/segregation and block- ing/bracing. For more information about
hazardous materials shipping, visit the PHMSA at
www.phmsa.dot.gov/ portal/site/PHMSA. For information specifi cally about air travel and hazard- ous materials visit the DOT SafeTravel website at
safetravel.dot.gov.
Class 2 Gases
Class 3 Flammable Liquids
Class 7 Radioactive Materials
Class 8 Corrosives
Class 9 Miscellaneous Dangerous Goods
Fig 1. Hazardous materials are separated into these classes. May 2013 MODERN CASTING | 75
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