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[Updated 06/24/2008 (08-05 (TED 01))]

Effective Date: 1/20/1999
Directive Number: TED 01-00-015 [TED 1-0.15A]


SAMPLE SHIPPING AND HANDLING
  1. Introduction
  2. Shipping Instructions
  3. Federal Shipping Regulations

  1. 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.

  2. 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.

  3. 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:

      1. Explosives

      2. Gases

      3. Flammable Liquids

      4. Flammable Solids

      5. Oxidizing Substances and Organic Peroxides

      6. Toxic and Infectious Substances

      7. Radioactive Materials

      8. Corrosives

      9. 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.