Environmental Health and Safety

Shipping and Transporting Research Materials and Dangerous Goods

Shipping and Transporting Research Materials and Dangerous Goods

If University faculty, staff, or students plan to arrange or offer small quantities of chemical, biological, other hazardous or research-related materials for transport to analytical laboratories, collaborators, etc., consultation with EHS is required.

Properly trained and certified EHS staff will identify the necessary requirements for hazardous material transport and assist laboratory personnel in correctly packaging and labeling shipments.

Importing chemical samples or research materials

When importing chemical samples or research materials, refer to the main Toxic Substance Control Act (TSCA) webpage for guidance on the import of chemicals.

Visit TSCA

Complete the following steps when submitting a shipment request

  1. Check to see if you need a Material Transfer Agreement (MTA) with your shipment.
  2. For international shipments, check to see if an export permit is required.
  3. Complete the TSCA Form (PDF) for all shipment requests containing hazardous chemicals.  Shipments containing biological materials and non hazardous chemicals do not need the TSCA form completed.
  4. Download the Safety Data Sheets of all hazardous chemicals to be included in the shipment.
  5. Submit the shipment request form. EHS will respond to shipment requests within 3 business days.

Ship a Sample Request Form

Researcher Responsibility

  1. Provide container(s) and packaging that meets requirements outlined in provided shipping instructions. Instructions are provided to aid in the preparation of potential shipments/packages and cannot be used to ship without prior EHS review and approval.
  2. Create and print the shipping label (i.e., FedEx air waybill). Department staff or administrators may be able to provide assistance.
  3. Provide all required material documents (SDS, Export control permits, etc.).
  4. Source and weigh dry ice, if applicable.

EHS (Shipper) Responsibility

  1. Review and determine the classification of shipment requests.
  2. Provide shipping instructions.
  3. Work with researchers to complete hazardous or regulated shipments, including providing required labels.

Shipping Instructions

Instructions are provided to aid in the preparation of potential shipments/packages and cannot be used to ship without prior EHS review and approval.

Regulatory Applicability

Brown University is legally required to comply with applicable Department of Transportation (DOT), Federal Aviation Administration (FAA), and International Airline Transportation Association (IATA) guidelines and regulations when shipping regulated materials. Specific training is mandatory for shippers and handlers and is based on these regulations. The transportation of certain materials may require export permits or other documentation in compliance with regulatory agencies.

Shipping hazardous materials can pose a danger to anyone who may come into contact with the shipment.  The individual performing the shipment can be held responsible for non-compliance with transportation regulations. When offering a substance for transport, Brown University becomes the legal shipper. Violations to the University’s shipping program include shipping regulated materials without EHS, shipping regulated materials using an EHS name as the shipper without their consent or approval, and shipping regulated materials without proper packaging or labeling. These violations can be met with legal and/or monetary penalties by regulatory agencies.

Brown’s Export Control Program

Brown University is committed to supporting research and protecting Openness in Research through compliance with all applicable internal policies, procedures, practices, and guidance, as well as federal and local laws and regulations, including those related to export control. For further information, see the Export Control Policy 

When shipping biological or hazardous materials outside the U.S., you must ensure that an export license is not required by the U.S. Department of Commerce or Department of State prior to shipment.  Brown’s Export Control Team can help you determine the Export Control Classification Number (ECCN) of your material as well as whether an export license or additional documentation is required.

More information regarding international shipments and export controls can be found on the Export Control website or contact the Export Control Team at exportcontrol@brown.edu.

Material Transfer Agreements

A Material Transfer Agreement (MTA) signed by Brown’s Research Agreements and Contracting (RAC) office may be required before research materials leave campus. Contact RAC to discuss whether your research materials need an MTA before scheduling your shipment. For more information, visit RAC’s MTA page and contact researchcontracts@brown.edu with any questions.

Transportation of Regulated Materials during Laboratory Moves

Hazardous chemical containers may be transported from Brown University to an off-site location during a laboratory closeout.  If a Principal Investigator leaving Brown University chooses to transport their chemicals to an off-site location, a specialized chemical moving contractor to facilitate the compliant transport of hazardous materials is required as described in the Laboratory Closeout Policy.

Shipments from Brown University of original manufacturer products that are hazardous are not permitted other than during a laboratory closeout.

Questions

For questions, contact research_shipping@brown.edu