| Directive Number:
08-05 (TED 01) |
| Effective Date: 6/24/2008 |
SECTION II: CHAPTER 4
SAMPLE SHIPPING AND HANDLING
Contents:
- Introduction
- Shipping Instructions
-
Federal Shipping Regulations
- Introduction
This chapter contains sample handling, packaging, and shipping instructions to
be used by OSHA Compliance Safety and Health Officers (CSHOs) to ship
industrial hygiene, safety and construction samples to the Salt Lake Technical
Center (SLTC). Certain Department of Transportation (DOT) regulations, 49 Code
of Federal Regulations (CFR) or regulations described in the International Air
Transport Association (IATA) Dangerous Goods Regulations Manual, may apply to
the shipment of materials. The SLTC has experts that have received training in
shipment of these materials. OSHA CSHOs should contact the SLTC for guidance
in these matters if they have any questions. Serious fines can be assessed for
the improper shipment of hazardous materials.
Samples sent to the SLTC shall be packaged together with a copy of Form
OSHA-91A. In order to protect the chain of custody, all compliance samples
must be shipped with some form of tracking, either U.S. Postal Service (USPS)
certified mail, or comparable service by a private carrier. If a sample cannot
be shipped to the SLTC by USPS certified mail, an alternate mode of shipment
(Federal Express, Emery Air Express, United Parcel Service, etc.) can be used.
In certain cases, overnight shipment is necessary. Examples include certain
hexavalent chromium and methyl ethyl ketone peroxide samples. Consult OSHA's
Chemical Sampling Information file or contact the SLTC for guidance.
At the time of this revision, the noted shipping agencies offer several
convenient services to assist CSHOs when preparing to ship samples. For
instance, USPS offers mailing boxes for Priority Mail packages at no cost. The
only charge is the cost of Priority Mail service. Priority Mail cost is the
same as first class mail for weights over 11 ounces. Local post offices will
deliver a pre-requested number of boxes as part of a regular subscription
service. Extra boxes can be obtained at local post offices. Federal Express
also provides shipping boxes at no cost and they will also accept any box with
their shipping label.
- Shipping Instructions
Safe shipping begins in the field when the CSHO starts to collect the desired
substance or material to be shipped and analyzed at SLTC. Every effort should
be made to keep the exterior of the container free of the substance being
sampled. This will prevent taking unwanted material back to the area office as
well as minimize the potential hazard to SLTC personnel who open the shipping
package and begin removing samples for evaluation.
Be certain that each sample is properly sealed with a Form OSHA-21 label and
is accompanied with a properly completed Form OSHA-91A. Samples should be
shipped in boxes or other sturdy containers with sufficient packing material
to fill the box. Samples should be placed in proper containers (e.g., bulk
samples in 20-milliliter (mL) scintillation vials). Do not ship bulk samples
with air samples.
A. Filter Cassette Samples
Samples should be placed in a plastic bag. Do not use or place expanded
polystyrene packing (StyrofoamTM) or any static-producing materials, such as
polycarbonate, polytetrafluoroethylene (PTFE or TeflonTM), polyvinyl chloride
(PVC) and polystyrene plastic in containers with asbestos or other fibrous air
samples. Do not use vermiculite. Loose vermiculite packaging material is not
recommended due to its potential contamination of the sample cassette with
excessive dust, and its tendency to attract a static charge which could affect
the fiber count. Corn starch "peanuts," excelsior (shredded wood fiber) and
some anti-static commercial products do not produce static electricity.
B. Diffusive and Adsorbent Tube Samplers
Sampling tubes should be bundled with a rubber band or placed in a plastic bag
so that they cannot separate and get lost in the packaging material. Diffusive
samplers must be properly closed with the manufacturer-supplied components.
C. Impinger or Fritted Glass Bubbler Samples
Transfer the solution from each impinger or bubbler to a separate 20-mL glass
vial. When filling containers with liquids, leave sufficient space at the top
of the container to allow for expansion of the liquid. Ensure that the cap
contains the proper liner (e.g., PolySealTM, PTFE, etc.). Tighten the cap
snugly, and with the vial upright, wrap elastic tape clockwise around the cap
so that the tape will tighten the cap. Also, verify that the cap liner is not
warped due to over-tightening.
Ship samples by USPS certified mail if they are not hazardous according to
DOT/IATA regulations. If the sampling solution was provided by the SLTC and it
is a hazardous material according to DOT/IATA regulations, an instruction
sheet describing the required labeling and packaging for return shipment is
provided. Examples of some hazardous materials include isopropyl and methyl
alcohols; hydrochloric, sulfuric, and sulfamic acids; and hydroxyl ammonium
chloride-sodium hydroxide mixed solution. OSHA CSHOs should contact the SLTC
for assistance if they have questions about shipping the material.
D. Wipe Samples
Wipe samples/filters should be shipped in 20-mL glass scintillation vials. If
a hazardous solvent was used to wet the filters, proper labeling and packaging
may be required. Wipe samples must be identified as such on the Form OSHA-91A.
E. Gas Sampling Bags and Canister Samples
Gas sampling bags should be filled to less than 75% capacity to allow for
expansion due to differing atmospheric pressures. Bags that are known to
contain dangerous concentrations or odiferous gases should be shipped by
ground transportation.
F. Bulk Samples
Bulk samples should never be shipped to the SLTC in the same package with air
samples. They should generally be shipped in 20-mL glass vials with PTFE-lined
caps. Tighten the cap, and with the vial upright, wrap elastic tape clockwise
around the cap so that the tape will tighten the cap. Label the vial with the
appropriate sample submission number. If the material is hazardous according
to DOT/IATA regulations, the package must be properly labeled, packaged, and
shipped. OSHA CSHOs should contact the SLTC for guidance if they have
questions about shipping the material.
The Form OSHA-91A must identify the shipped material as a bulk sample and must
list the air sample numbers corresponding to the bulk sample. The air sample's
Form OSHA-91A should also indicate that an associated bulk sample is being
shipped, as well as the mode of shipment. If available, include a copy of the
material safety data sheet for the bulk sample.
G. Explosibility Samples
Bulk samples for explosibility determination should be shipped in 1-L plastic
bottles which can be obtained from the SLTC. If the material is hazardous
according to DOT/IATA regulations, it should be properly labeled and packaged.
OSHA CSHOs should contact the SLTC for guidance if they have questions about
shipping the material.
H. Soil Samples
Soil should be placed in a heavy-duty and tear-resistant plastic bag, secured,
and sealed with tape to be airtight. Place the first plastic bag in a second
heavy-duty plastic bag for additional protection. Sample size can vary from
one pint for very fine-grained samples to two quarts for coarse gravel. A
typical sample should be approximately one quart and weigh about three pounds.
The Form OSHA-91A should not be put directly in the bag with the soil.
- Federal Shipping Regulations
Hazardous materials are articles or substances that are capable of posing a
risk to health, safety, property, or the environment, and are listed as
dangerous goods in DOT and/or IATA Dangerous Goods Regulations Manual. When
shipping hazardous materials to the SLTC, Federal interstate transportation
regulations must be followed. These regulations may prohibit the use of USPS.
The shipper is responsible for compliance with applicable transportation or
postal laws and any additional regulations imposed by the carrier. The shipper
must comply with any packaging requirements such as proper labeling and
packing requirements. Each package must be large enough so that there is
adequate space to affix all required markings and labels. The correct labels
and forms must be used. All labels and forms must be complete, legible, and
accurate. Before packing any dangerous goods the shipper must:
- Identify correctly and fully all dangerous articles and dangerous substances
within the package.
- Classify each item of dangerous goods by determining under which of the nine
classes it falls:
- Explosives
- Gases
- Flammable Liquids
- Flammable Solids
- Oxidizing Substances and Organic Peroxides
- Toxic and Infectious Substances
- Radioactive Materials
- Corrosives
- Miscellaneous Dangerous Goods
- Determine any subsidiary hazards and assign each item of dangerous goods to
one of the three packing groups within the assigned class or division.
- Follow the appropriate packing and labeling requirements.
All items that are acceptable for USPS are subject to the provisions of Part
124, USPS Manual and Publication 52 of the USPS, Acceptance of Hazardous or
Perishable Articles.
The Transportation Safety Act of 1974 extended DOT's authority over
transportation of hazardous and restricted materials. The full text of the
hazardous materials regulations is contained in 49 CFR Parts 100-199.
Any goods shipped by air must be in compliance with IATA regulations. The SLTC
has staff with training in shipping of hazardous materials. OSHA CSHOs should
contact the SLTC for guidance in these matters if they have any questions.
49 CFR Part 172, Section 101-Hazardous Materials Table is key to understanding
current DOT regulations for domestic shipment of hazardous materials. If
hazardous materials are to be shipped internationally, then either the
International Civil Aviation Organization (ICAO) technical instructions or the
IATA dangerous goods instructions must be followed. To ensure that current
regulations are followed, it is important to use only the most recent edition
of 49 CFR and the ICAO or IATA instructions.
USPS and private carriers base their shipping procedures for hazardous
materials on DOT 49 CFR regulations. These regulations are the minimum
requirements acceptable for shipping hazardous materials. Some carriers are
more restrictive than the DOT regulations. The shipper must comply with the
carrier's requirements. When a restricted article is tendered for shipment,
the customer is required to properly identify, classify, package, mark, label,
and certify that all requirements specified in 49 CFR are completed. For all
modes of transportation, the carrier must be clearly informed that hazardous
material is being tendered.
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