ONLINE SELF-STUDY

Shipping with Dry Ice

Introduction

The Department of Transportation considers dry ice to be a

hazardous material when shipped in commerce. Anyone who

prepares a package containing dry ice must be trained and verified

through testing on the applicable regulations for shipping dry ice.

After completing this training module and successfully passing the

10 question post test you will receive a certificate and be legally

certified to ship packages that contain dry ice.

This training is valid for two years. After two years if you wish to

continue shipping packages containing dry ice you must complete

this training again to be legally certified to do so.

Introduction

This module fulfills the training requirements for dry ice only.

Federal law requires training specific to all hazardous items

included in a package. If the items you wish to ship on dry ice are

considered hazardous (for example hazardous chemicals or

infectious substances) you must either complete the Shipping

Infectious Substances and Other Biomedical Materials training

module or contact EHS for training specific to your items.

Contact EHS for help determining if your items are considered

hazardous materials for shipping purposes.

If you have completed the Shipping Infectious Substances and

Other Biomedical Materials training within the last 2 years you are

already certified to ship items using dry ice for as long as your

certificate from that training is valid.

Course Objectives

The purpose of this training module is to:

Ensure the safe handling of dry ice using good sensible practices.

Comply with Federal and International regulations for packing,

labeling, and documenting shipments containing dry ice.

Course Objectives

This training will increase your awareness of safety and compliance issues. If you need more

information or help with shipping your package you can e-mail the EHS Shipping Specialist.

The training will cover the topics listed below. Classification, packaging, and marking and

labeling are the three most important topics covered.

Regulatory Oversight

Hazardous Materials Definition

Training Requirements

Penalties

Classification and Identification

Packaging

Marking & labeling packages

Documentation

Record Keeping

Emergency Response

Security Plan

Regulatory Oversight

Federal Regulations:

U.S. Dept. of Transportation (DOT) – 49 CFR

Federal Aviation Administration (FAA)

The DOT is the federal agency in charge of hazardous material

shipments in commerce. The FAA is a division within the DOT that

enforces hazardous material regulations on packages shipped via

air carrier. Unless you are using a specific ground only service (i.e.:

FedEx Ground) your dangerous goods packages will fall under the

FAA’s jurisdiction. If you are using a ground only carrier contact

EHS for further instruction as ground regulations differ slightly than

those for air shipments.

Regulatory Oversight

International Regulations (Air shipments)

International Civil Aviation Organization (ICAO)

International Air Transport Association (IATA)

Dangerous Goods Regulations (DGR)

For the international standard a UN Committee of Experts develops

recommended procedures for the transport of all hazardous materials

except radioactive material. The International Civil Aviation Organization

(ICAO) uses the UN recommendations as the basis for developing the

regulations for the safe transport of hazardous materials by air. The

International Air Transport Association (IATA) is the international trade

organization that interprets ICAO regulations and publishes the

Dangerous Goods Regulations (DGR), a user’s manual for the ICAO

regulations. The IATA regulations are more stringent than DOT. This

training module follows IATA regulations. IATA regulations are minimal

requirements - your carrier can be more stringent.

What is a Hazardous Material?

The DOT defines a hazardous material as:

“Any substance or material that the Secretary of Transportation has

determined to be capable of causing an unreasonable risk to health,

safety, and property when transported in commerce”

What is a Hazardous Material?

There are nine classes of hazardous materials defined by the DOT

and IATA:

1: Explosives

2: Compressed Gas

3: Flammable Liquids

4: Flammable Solids

5: Oxidizing Substances

6: Toxic or Infectious Substances

7: Radioactive Materials

8: Corrosive Materials

9: Miscellaneous Hazards

Dry Ice is a Class 9 Miscellaneous Hazard

Training Requirements

Any person who prepares a hazardous material for transportation in

commerce must be trained and tested on the subjects below as

they apply to the item they are preparing:

General Awareness – recognizing dangerous goods

Function Specific – how to pack, label and document your items

Safety Training – understanding the hazards associated with

your items

Security Awareness – understanding the security risks

associated with transporting your items

In-depth security training – specific security procedures followed

in your work environment

Penalties

"Violations contrary to the U.S. Code of Federal

Regulations (CFR) 49, if substantiated, may

result in the assessment of a civil penalty of up

to $37,500 per violation, and deliberate

violations may result in criminal prosecution of

up to $500,000 and 5 years in prison."

There has been an increase in the number of

Federal Aviation Inspections (FAA) in response

to the 1996 ValuJet crash, the September 11,

2001 attacks, and the UPS package bomb

scare in November 2010.

If you are receiving a HazMat package it is

your responsibility to ensure the sender

packages it correctly.

The FAA randomly inspects several labs at

UNC every year. The primary focus of these

inspections is to check for proper shipping

training and adequate hazardous material

shipment records.Oxygen-generating canister like the ones on

board the ValuJet flight 592 in 1996.

Identification and Classification

Dry Ice is a Class 9 Miscellaneous Hazard. It is considered a

hazardous material for the following reasons:

Explosion Hazard: dry ice releases large volumes of CO2 gas as

it sublimates. If it is kept in an air tight container the pressure

may cause a violent rupture.

Suffocation Hazard: dry ice can create an oxygen deficient

environment if stored in an area with poor ventilation.

Contact Hazard: dry ice’s low temperature can cause burns

similar to frostbite on human skin.

MSDS for Dry Ice: https://www.airgas.com/msds/001091.pdf

Packaging

To prevent an unintentional release or exposure, dry ice must be

packaged as follows:

In a container with sufficient insulation to not be adversely

affected by the cold temperature.

In a hard walled container that will hold up to bumps, shocks,

and drops and be resistant to punctures.

Note: Styrofoam coolers by themselves do not constitute a

sufficient hard walled container. Styrofoam coolers must be

placed inside a hard walled outer container such as a cardboard

box.

Packaging

An insulated container not

adversely affected by dry ice

temperature.

(NOT sufficient packaging by itself).

An insulated container not

adversely affected by dry

ice temperature inside of a

hard walled container.

(Sufficient packaging)

Packaging

Secure your items inside the package so that they will not move

around if the dry ice sublimates completely. Foam bracings,

packing peanuts, crumbled newspaper, and bubble wrap are a few

options. Another option is to tape your item to an inside wall of the

package.

To make the dry ice last longer fill any empty space inside the box

with crumbled paper or packing peanuts.

The maximum amount of dry ice allowed in a single container is 200

kg.

Packaging

A package containing dry ice must permit the release of CO2

vapors. Failure to do so can result in a violent rupture.

To ensure vapors can escape, do not seal the lid of the inner

Styrofoam container.

Tape only the center where the flaps meet on top of the box.

Marking and Labeling

Every package containing dry ice must have a Class 9 Miscellaneous hazard label (minimum size 4 in x 4 in):

For a .pdf version of this label go here:

http://ehs.unc.edu/files/2015/09/dry_ice.pdf

Note: Labels must be weather resistant. If

you use the paper label in the link above be

sure to completely cover it with clear packing

tape when you attach it to the box.

Effective October 1, 2014

Per the DOT regulations, Class 9 hazard labels with the horizontal line

the will no longer be accepted.

Marking and Labeling

Every dry ice package must have one of the following markings adjacent

to the Class 9 label:

Carbon dioxide, solid, UN1845 (net weight of dry ice)KG

Or

Dry Ice, UN1845 __(net weight of dry ice )_ KG

Marking and Labeling

Every dry ice package must display the name, address, and phone

number of both the sender and receiver of the package.

Use arrows on two opposite

sides to indicate the proper

package orientation (only

required for liquid items).

Marking and Labeling

The class 9 label, sender and receiver information, and Dry Ice,

UN1845 ___ kg markings should be on the same vertical side of the

box.

Do not put these markings on the top or bottom of the package.

The label must not overlap other required markings and must not

wrap around to another side of the box (any portion of the label).

Label must not cover any required

markings

Label must not wrap around to

another side of the box

Documentation

You must indicate on the air waybill / shipping paper that your

package contains dry ice. For most carriers this involves simply

checking a box and entering the net weight of the dry ice.

Documentation

If you are filling out a shipping paper without a dry ice check box you

need to write the following in the Description of Goods section:

Dry Ice,9,UN1845 (# of packages) x_(net weight in kg)

If you are unsure check with the carrier or contact EHS to determine if

you have marked the shipping paper correctly.

Record Keeping

Keep a record of all shipments from your facility for 2 years

(domestic shipments) or 5 years (international shipments).

Records should include at minimum a copy of the air

waybill/shipping paper, a list of package contents, and a note of who

prepared the package if it is different than the name on the shipping

paper.

International shipments must include copies of all paperwork

associated with the shipment including commercial invoices and

other customs documentation.

Emergency Response

Review your lab safety plan and the EHS lab safety manual

(http://ehs.unc.edu/manuals/laboratory/) for safety information

specific to your lab.

Never touch pellets or blocks of dry ice bare handed. Use gloves or

mechanical means (scoop, broom and pan) to clean up spilled or

dropped dry ice.

Never store dry ice in a poorly ventilated room as this will create an

oxygen deficient environment.

Never store dry ice in an air tight container as this will create an

explosion hazard.

Emergency Response

Important points to consider when receiving a damaged shipment

How do you know that a package contains hazardous materials? Look

for the red hatch marks on paperwork, UN # and diamond shaped

labels on box.

A damaged package may be crushed or leaking.

Do not sign for packages without seeing them

Inspect package before signing

Do not accept a package that is damaged

Packages are the responsibility of the Shipper until accepted by

recipient

If the package is damaged or leaking offer assistance in cleaning up

the spill (call EHS). The carrier should be prepared to deal with the

spill.

Emergency Response

Emergency Response for Damaged Package or Spill on Campus

In a laboratory setting it is expected that staff are prepared to cope

with a spill.

All labs should have an emergency spill kit on hand and train all

personnel in appropriate emergency response.

Isolate spill or leak area immediately in all directions.

Keep unauthorized personnel away.

Obtain the identity of the substance involved if possible and report

spill to appropriate authorities.

Do not touch or walk through spilled material.

Do not touch damaged containers or spilled material unless wearing

appropriate protective clothing.

If you need to, call EHS (962 - 5507) to help with spill clean up.

Emergency Response

Emergency Response for Damaged Package or Spill on

Campus

Be very careful to avoid contact with broken glass or sharp objects

that may cause cuts or abrasions that could significantly increase

the risk of exposure.

Damaged packages containing dry ice as a refrigerant may produce

water or frost from condensation of air. Do not touch this liquid as it

could be contaminated by the contents of the package.

Emergency Response

Emergency Response for Damaged Package or Spill on Campus

Absorb spilled materials with earth, sand or other non-combustible

material while avoiding direct contact.

Evaluate potential personal exposure.

Contact UNC Employee Occupational Health Clinic (966-9119) for

post exposure follow-up.

Security Plan

If you ship dangerous goods you should adopt, implement and

comply with a security plan that addresses the elements specified in

section 1.6.3.2 of the IATA Dangerous Goods Regulations

Labs need to take specific action in order to provide security against

theft of highly hazardous materials, and to ensure compliance with

new regulations.

EHS urges each lab/clinic to review and develop procedures to

ensure the security of hazardous materials in your area.

Security Plan

You may already implement the necessary security measures such

as:

Locking up controlled substances, syringes, and needles

Securing radioactive material

An easy way to increase laboratory security is to lock the lab

whenever it is left unattended

Keep records of hazardous materials or types of hazardsou

materials transported

Review how you store your hazardous materials

Put in place procedures for reporting and dealing with security

threats, breaches of security, or security incidents

Security Plan

You should control access to areas where hazardous chemicals are

used and stored.

Lock freezers, refrigerators where biological agents, hazardous

chemicals or radioactive materials are stored in common areas.

Approach anyone you don't recognize who appear to be wandering

in lab areas.

Assign security responsibility to one employee in your lab. Give

them appropriate authority to carry out their responsibilities.

Security Plan

Use a log book to sign highly hazardous materials in and out of

secure storage.

Take a periodic inventory of highly hazardous chemicals, biological

agents/toxins, radioactive material and controlled substances.

This could be as simple as frequently looking at your chemical

containers to make sure none are missing.

Track the use and disposal of hazardous materials. Report any

missing inventory to Public Safety or EHS.

Know what materials are being ordered and being brought into the

laboratory.

Consider having all lab staff wear identification badges.

Additional Resources

Contacts for Dry Ice packaging materials

SAF-T-PAK

Edmonton, Alberto, Canada

800-814-7480

www.saftpak.com

CARGOpak, Corp.

Raleigh, NC

800-266-0652

www.cargopak.com

Fisher Scientific

800-766-7000

www.fishersci.com

Additional shipping resources at UNC-Chapel Hill:

UNC EHS Shipping web page: http://ehs.unc.edu/lab/shipping/

UNC Export Control web page: http://ehs.unc.edu/biological/ec/

Checklist for shipments containing

dry ice

_____ Total quantity per package is 200 kg or less

_____ Package in contact with dry ice is sufficiently insulated

_____ outer package is hard walled (ie: cardboard not styrofoam)

_____ Package is vented or able to permit release of Carbon Dioxide gas

and to prevent pressure build up

_____ Material inside the outer package is secured so that it will not shift once

dry ice dissipates

_____ Outside of box marked UN1845, Carbon dioxide, solid and Net

Weight of dry ice

_____ Class 9 label on outside of box

_____ name address and phone number of sender and receiver on the outside

of the box

If the material you are shipping qualifies as a dangerous good you must meet the

packing requirements for that item IN ADDITION to these requirements for dry

ice.

Summary

This training certifies you to ship non-hazardous items on dry ice. If the

item you wish to ship is considered hazardous contact EHS for further

instruction.

Dry ice may present an explosion, suffocation, or burn hazard – use

caution when handling dry ice and always do so in a well ventilated area.

Never store dry ice in an air tight container.

Protect yourself, your coworkers, and the public by following the

procedures in this training for shipping packages containing dry ice.

Hazard communication is fundamental (proper labeling and

documentation)

Contact your carrier for specific information regarding shipping packages

with dry ice. All destinations may not be served.

When in doubt ask for assistance - Call EHS (962 – 5507)

In order to receive credit for this training, you must complete the post-test