Environmental Health and Safety

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

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. Maintain a copy of the required Safety Data Sheets for all materials to be included in the shipment.
  4. Complete the Toxic Substances Control Act (TSCA) Form (PDF) for all shipment requests containing chemicals.  Shipments containing only biological materials do not require the TSCA form to be completed.
  5. Submit the shipment request form including all required documents. EHS will respond to shipment requests within 3 business days. EHS will provide written instructions for shipping.

Submit a Shipment Request

Preparing a Sample for Shipment

Individuals who are requesting to ship a sample will need to:

  1. Obtain appropriate inner container(s), packaging, box, etc. that meet the requirements outlined in the 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. Obtain and weigh dry ice as applicable.
  3. Coordinate with your department or designated stockroom shipping staff to prepare a FedEx label.

Shipping Instructions

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. Brown University becomes the legal shipper for materials considered hazardous for transportation. Non-compliance with the University’s shipping program includes, but is not limited to:

  • shipping regulated materials without EHS approval,
  • shipping regulated materials using an EHS name as the shipper without their consent,
  • and shipping regulated materials without proper packaging or labeling. 

These violations can result in legal and/or monetary penalties from regulatory agencies.

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.

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.

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.

Questions

For questions, contact research_shipping@brown.edu

Resources