Transportation for Chemicals Used In Demonstrations or Educational Activities

Using small amounts of hazardous materials in chemical demonstrations and/or educational activities is permitted under U.S. Department of Transportation (USDOT) regulations. Chemicals purchased at the hardware store or grocery store are also subject to the same USDOT regulations. According to 49 CFR 173.6 Materials of Trade Exceptions, the amount of material allow is determined by the chemicals’ hazard class/division and packing group. Hazard class/division is defined by the type of material while packing group is assigned based on the level of hazard the material possess during transportation. The packing group is classified under three categories: I for great danger, II for medium danger, and III minor danger. The hazard class/division and quantity limits is listed in the table below.

*ORM-D (Other Regulated Material for Domestic Transport Only) is a marking for shipping that can be found on consumer commodities of hazardous material.

*Refer to 49 CFR 173.6 for the latest updates on quantity limits.

Federal Regulations

For chemical transportation on demonstrations and/or educational activities: 

• Explosives especially on all Hazard Class 1 are ineligible for Materials of Trade Exceptions.
• Materials of Trade Exceptions does not apply to any self-reactive materials, poison-by-inhalation materials, or hazardous wastes regardless of hazard class/division.
• Container must be leak-proof for liquids and gases and sift-proof for solids.
• Container must be properly closed and secured, protected against shifting during transportation, and protected against damages.
• Chemical must be packaged in the manufacturer’s original packaging or a packaging of equal or greater strength and integrity.
• Outer packaging is not necessary for receptacles (e.g., cans/bottles) that are secured against shifting in cages, carts, bins, boxes, or compartments. 
• For gasoline transportation, the container must be made of metal or plastic and follow the other USDOT and U.S. Department of Labor/Occupational Safety and Health Administration (DOL/OSHA) regulations, specifically 29 CFR 1910.106(d)(2). The use of glass container is PROHIBITED with gasoline. 
• All Division 2.1 or 2.2 compressed gases are required to follow the USDOT regulations.
• All non-bulk packaging of a Material of Trade Exceptions must be marked with the common or proper shipping name to identify the material. If the Reportable Quantity is exceeded, write “RQ” on the outside packaging. For information on reportable quantities, refer to Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-Know Act (EPCRA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and Section 112 ® of the Clean Air Act, as Amended, better known by the short title “SARA Title III List of Lists.” 
• For all bulk packaging of diluted Hazard Class 9 material mixture, the packaging must be marked on two opposing sides with the 4-digit identification number and properly displayed on the proper placard. Please contact EHS for assistance if necessary.
• Vehicle operator must be inform of the hazardous material presence, whether it is within a Reportable Quantity, and the 49 CFR 173.6 requirements.
• The combined gross weight of all chemicals in a motor vehicle cannot exceed 200kg. 

Guidelines for hazardous material transportation:

• Use chemicals unregulated by USDOT when possible. 
• Refer to the Safety Data Sheet (SDS) Transportation section for guidance on determining the proper shipping name/basic description for documentation or lists preparation. If possible, consult with the USDOT Hazardous Materials Table for the proper shipping name of the materials.
• All personnel transporting hazardous materials must have taken the SMU-offered Laboratory Safety Training.
• Attend USDOT Hazardous Materials Regulations training before shipping determination. USDOT’s training module on determining proper shipping names from can be access here.
• If possible, use the lowest amount and concentration of chemical for demonstration or educational purposes.
• Use chemical compatible packaging only.
• Containers must be properly labeled with the chemicals name and concentration.
• Each individual chemical container must be place in a secondary packaging to prevent chemicals aggregation.
• Avoid transporting hazardous materials in the passenger area of the vehicle. The trunk or bed of the vehicle should be used if possible.
• Incompatible chemical must be stored separately.
• Glass containers should be avoided at all times.
• Chemical container must be cushioned with absorbent material.
• A spill kit and SDS are required during hazardous material transportation.
• Use only University vehicles for hazardous materials transportation.
• Any questions regarding the hazardous materials transportation should be directed to EHS at 214-768-2430.

_{Source: American Chemical Society. (November 2018). Safe Transportation Recommendations for Chemicals Used in Demonstrations or Educational Activities. Retrieved from https://www.acs.org/content/acs/en/about/governance/committees/chemicalsafety/publications.html.}