DATE:             November 7, 2011

TO:                  NMSU ABCD email distribution

FROM:            Dr. Katrina Doolittle, Director for Environmental Health & Safety

SUBJECT:      NMSU Hazardous Material Shipping & Transportation Procedures

This memo outlines NMSU procedures for safe shipping and transportation of hazardous materials that are shipped through a public contractor, for example UPS, FedEx, U.S. Postal Service, etc.  Please distribute this to all faculty, staff, and students that may need to ship chemicals, pesticides, biological, radioactive materials or dry ice.  Following these simple procedures will best ensure we stay compliant with applicable laws and ultimately protect public health.

The Department of Transportation (DOT) has strict and complex regulations governing the shipment of hazardous materials through public contractors.  Shipping personnel must have specialized training and ensure specific packages, labels, and paperwork are properly used and have a 24 hour emergency response number. 

Shipping Hazardous Materials - from Las Cruces campus

  1. Anderson Hall Shipping has been designated as the central hazardous material shipping center. 
  2. To use this service, the Hazardous Materials Shipping form must be completed 24 hrs in advance of the shipment and submitted to lpsanchez@psl.nmsu.edu. Call Louie Sanchez at 575-646-9488 if you have questions. 
  3. All radioactive materials shipments must be approved by and coordinated through NMSU Radiation Safety Manager.

Hazardous materials shipping outside the Las Cruces area

  1. The NMSU employee responsible for shipping must be trained before performing hazardous materials shipping duties and retrained every three years ( 49 CFR 172, Subpart H, HM-181 and HM-126F).  The course must provide security and general awareness and function specific training for those involved in hazardous materials transportation compliance.  Training and testing must be documented.
  2. The shipper must have proper packaging materials according to DOT 49 CFR 172.  
  3. All radioactive materials shipments must be approved by and coordinated through NMSU Radiation Safety Manager.

Guide to Shipping with Dry Ice
Dry ice is a hazardous material and is regulated under the DOT.  Federal law requires appropriate training for anyone wanting to ship dry ice.  The NMSU Guide to Shipping with Dry Ice provides specific procedures that must be followed including becoming certified to ship dry ice as long as no other hazardous materials are involved.

DOT requirements for hazardous material security procedures
The bottom line on security is that all hazardous materials must be locked up when not in use or out of eyesight.  Stolen, lost, or missing hazardous materials, or suspicious activities involving hazardous materials, need to be immediately reported to Environmental Health & Safety (575-646-3327) and the NMSU Police (575-646-3311).

Hazardous materials transported by government employees in government vehicles
There may be an exemption for NMSU employees when they transport hazardous materials for official business in an NMSU vehicle.  An example would be a NMSU researcher transporting a herbicide from campus to a farm.  In this situation, coordination with Anderson Hall shipping center is not necessary. Although formal DOT training is not required in this situation, extra precautions should be taken.  For example, keep hazardous materials in their original packaging and maintain clear labeling, place them in secondary containers, and keep a spill kit accessible.

DOT regulations are often difficult to interpret for academic and research activities so if you want to transport hazardous materials under the government vehicle exemption or have unusual questions please contact the respective technical expert.

  • Chemicals or Hazardous Waste – Greg Vogel, EH&S Hazardous Materials Specialist, HZWPER
  • Radioactive Materials or Radioactive Waste - David Schoep, EH&S Radiation Safety Manager
  • Biological Materials – Dr. JoAnne Dupre, Biosafety Manager 646-4463 

 

November 2011 - NMSU EH&S Memo (pdf format)

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