Hazmat Question

[getonit]

Thought I would post this question here, seeing as how you guys probably know more about this.

Our company has a no hazmat in our ops specs, ie we can't carry anything. I believe our ops specs say passenger only or something similar. We recently dropped off a passenger(doctor) and picked up her tissue medical samples to be taken back. The box was labeled UN 3373, and a label "BiologicalCategory B" on it. My question is this Hazmat, our company said No, but I really don't believe them. I honestly don't believe it was dangerous, but I don't like to do things against the rules. Any references so I can make the argument next time would be appreciated.

 

[iaflyer]

Hazmat is a complicated subject and can get a company into trouble if not done carefully and I am not an expert in hazmat.

That being said, I suspect that the company was pulling the wool over your eyes - why else would the box have a UN number if it wasn't hazmat? When we carried freight, if it had a UN number it was hazmat. If it did not - it wasn't hazmat. There can be serious risks if a dangerous good isn't packaged correctly or is loaded improperly. Also, reusing a container that was marked as having hazmat but does not is also a violation of the dangerous goods regulations.

Biological Category B is the description of what kind of dangerous good it was. Be aware that there are serious (like $10,000 per incident) fines if the FAA discovers violations of DG regulations. Be a professional and do the research to discover what kind of trouble you could be in.

 

[Caboclo]

It is possible for a package to have a UN number, but not be subject to hazmat regulations, such as in limited quantities. I'm not an expert and I can't comment directly on your case since I don't have the regs in front of me, but I too have carried medical samples which were not considered hazmat. I realize that's not a very definite answer; I'm just saying you shouldn't start cussing out your boss just yet.

 

[LivestockTony]

UN3373 is the old 'Diagnostic Specimens' identifier. There are packing requirements, but I _don't think_ that it requires a shippers dangerous goods declaration, so it's quite possible to not get hazmat paperwork with it.

But I'm not a hazmat guy either. Your company ought to have someone that at least has "The Book" which will tell you how you screwed up. Or you can look it up yourself, domestic hazmat is covered in 49 CFR parts 100-185.

-TF

 

[Way2Broke]

UN 3373


Identification
Proper shipping name of UN 3373 is Diagnostic specimens or Clinical specimens
Packing Instructions, Marking and Labeling
Category B Substances will be packed under Packing Instruction 650. Changes to Packing Instruction 650 include:
The quantity limits have been revised to permit up to 1 L per primary receptacle, with a total of 4 L per package for liquids. For solids the package limit is 4 kg, the primary receptacle may contain up to 4 kg.
As with PI 602, the outer packaging must be rigid.
The packing instruction has also been amended to permit small quantities (30 mL or less) of substances in Classes 3, 8 or 9 to be packed with the infectious substances.
The mark illustrated below must be displayed on the external surface of the outer packaging. The mark must be in the form of a square set at an angle of 450 (diamond-shaped). The mark must be at least 2” X 2” and include the UN number- UN3373. The proper shipping name “Diagnostic specimens” or “Clinical specimens” must be marked on the outer package adjacent to the diamond-shaped mark.

When packages are placed in an overpack:
The overpack must be marked with the word "OVERPACK”
The package markings must be reproduced on the outside of the overpack
Infectious substances assigned to UN 3373 which are packed and marked in accordance with Packing Instruction 650 are not subject to any other requirement of these Regulations except for the following:
The name, address, and telephone number of a responsible person must be provided on the air waybill or on the package.
Incident reporting requirements must be met.
Inspection for damage or leakage requirements must be met.
Please note, air carriers will begin adhering to the 2005 IATA Dangerous Goods Regulations January 1, 2005. In the United States, the Federal Aviation Administration is resident at the major U.S. carriers and enforces the rules on the carriers. It is likely that non-compliant packaging will be refused or returned if the changes to the DGR have not be adopted by shipper’s of Infectious substances and Diagnostic specimens.
If you are a WU employee who received training in 2004 you will need to attend an update training session prior to shipping. These sessions can be arranged for large groups by calling Tracy Brodt at 362-6866. There will also be “Update” sessions scheduled in January and February, these sessions will be posted on the EHS website at www.ehs.wustl.edu. Click on “Training”.
Please contact Tracy Brodt (362-6866) if you have questions about the changes to the regulations.

 

[OzBushWhacker]

Your Good

From the DHL SOP's i was provided with when i ran into this and questioned it:


UN3373 "In order to identify diagnostic specimens within the regulations, ICAO-IATA have chosen to appoint a UN number (3373) to the commodity 'Diagnostic Specimens' ."

"While this number is assigned, it is NOT a Dangerous Goods designation but it intended to distinguish the specimens in Category B as NOT DANGEROUS GOODS (my caps)."

"Packing Instructions 650 are required. (i.e Markings etc)"

 

[Way2Broke]

The CFAR 49 that I have at the house is a bit out of date (2004). 3373 is not even in there, I guess it is a new designation.

 

[ACT700]

It is possible for a package to have a UN number, but not be subject to hazmat regulations, such as in limited quantities. I'm not an expert and I can't comment directly on your case since I don't have the regs in front of me, but I too have carried medical samples which were not considered hazmat. I realize that's not a very definite answer; I'm just saying you shouldn't start cussing out your boss just yet.

What he said.

Also, hazmat is not in the ops specs, it is on its own. Either you are will carry, or will not carry.