How Do I Safely Transport Hazardous Materials Without Violating Regulations?

Posted by Dr. P. Andrew Karam on 11/9/2015
So you want (or need) to transport hazardous materials? Most people would probably ask “why”; if you work with hazardous materials on a regular basis you know why you’re transporting the materials – a better question is “how do I do it safely without violating any regulations?” I can go over some of the basics here, but if you’re transporting hazardous materials then you really need to schedule yourself (or one of your minions) for formal training on the subject. That being said, here are some of the basics – especially in areas where people tend to make mistakes. Incidentally, we should also make sure we’re on the same page. “Shipping” means that you are packaging your materials but someone else is taking them from place to place. “Transporting” means that you are the one moving the package. Also, it only matters when you’re moving items over public roads – if you’re only taking things from place to place on, say, an industrial campus where the public does not have access then you don’t have to worry about most of this – although it’s never a bad idea to be careful!

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First of all, you’re going to need to familiarize yourself with the regulations – in particular, 49 CFR 171, 172, and 173. If you’re shipping or transporting radioactive materials then you really ought to be familiar with the relevant regs. I’m not going to go into all of that here – there’s too much to cover in a short blog posting, not to mention that you have to have formal training in the matter. So with that as a caveat, let’s get started.

One of the big places where people can make mistakes is with improper packaging. The regulations are fairly specific – 49 CFR 173 lays out the requirements in this area – and if you don’t have the proper packaging then you really need to find some. There are a number of companies that sell approved packaging; but make sure that the packaging you buy is certified to meet the regulatory requirements and make sure that you get a copy of the certification when you buy the packaging. Alternately, you can certify your own packaging by subjecting it to the tests laid out in the regs – dropping it onto a hard surface from a specified height for example, testing it for puncture resistance, and so forth. What you cannot do is to re-use a package that someone else used to ship materials to you – whatever certification used by the manufacturer doesn’t necessarily transfer to you unless you are able to certify that you tested them to ensure they are still legal. If you’re going to be shipping or transporting frequently then you’ll probably want to certify your own package (or find a low-cost vendor); if you’re shipping or transporting only infrequently then it’ll be easiest and cheapest to either buy single-use packages. And if you’re transporting your own materials in your own vehicles, you might even consider buying reusable certified packages.

Along the same lines, you also have to be careful to mark and label your packages properly and (possibly) to placard your vehicles. There are some subtleties in these rules. With radioactive materials, for example, whether or not the radioactive materials are considered to be “normal form” or “special form” makes a big difference in how they are labeled – and (again for radioactive materials) the package label determines whether or not the vehicle carrying the materials has to be placarded. The bottom line is that you’re responsible for making sure that your packages are properly labeled; if you’re transporting the materials yourself then it’s also your responsibility to placard your vehicle properly.

Of course, once the package is in the vehicle it’s a good idea to make sure it stays put. If you’re shipping something with another carrier then this isn’t really your problem; if you’re transporting your own packages then it is. What you really need to do is to make sure that the package will stay put – you don’t want it to be sliding around or bouncing out onto the road. In addition, it’s a good idea to take some precautions to keep someone from stealing your package. This means that your package(s) need to be properly blocked and braced (to prevent sliding and bouncing) and secured against theft. There are companies, for example, that have racks custom-made to hold the size packages they normally use; packages are placed into the racks (sometimes locked in) and the racks themselves are locked into the trunk of a car, welded into the bed of a pickup truck, or otherwise fastened down in whatever vehicle is being used. A company I used to work for didn’t quite understand this; when bouncing over some unfinished roads a soil density gauge bounced out of the bed of their pickup truck and was lost for over two years – it finally showed up again in a neighboring state (we never did figure out how it got there).

There’s a lot more to shipping and transporting hazardous materials than what’s been discussed here, but there’s no way to get into all of the details without giving the equivalent of a short course. And bear in mind that what’s been written here doesn’t even get into things like tanker trucks (or rail cars) and other transportation where the package can be the vehicle itself. But many of these are starting to get into more specialized circumstances that don’t apply to everyone, whereas the things mentioned earlier are common to most situations. So if I can leave with a few parting thoughts it would be to make sure you (or someone on your staff) receives the proper training, make sure you’re familiar with the regulations that apply to your own circumstances, be careful to use appropriate packages that are secured against shifting or theft during transportation, and make sure they’re properly marked and labeled. If you can take care of all of these things then you’re off to a good start.

About the Author: Andrew Karam is a board-certified health physicist with 34 years of experience in his field. He has earned a BA and MS in Geological Sciences and a PhD in Environmental Science, all from the Ohio State University. He has presented over 100 invited lectures and scientific talks at meetings in the US, Europe, South America, and Asia. Dr. Karam currently works on issues related to radiological and nuclear counter-terrorism; in the past he has been in charge of radiation safety for a major research university and hospital, as a professor at the Rochester Institute of Technology, and as a private consultant. He has also undertaken a number of projects internationally, working in Kuwait, Dubai, Paraguay, Uruguay, Cambodia, Cyprus, and Lithuania – his most recent overseas project involved traveling to Japan in the immediate aftermath of the tsunami and reactor meltdowns in Fukushima. He is the author of over two dozen scientific and technical papers, over 200 encyclopedia articles on various aspects of science, and several hundred editorials, essays, and articles for a variety of publications for both scientists and the general public. He has also written 16 books, including his memoir of life on a fast-attack submarine, Rig Ship for Ultra Quiet. Dr. Karam is married with five children and he currently lives in Brooklyn.

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