From: Russ Phifer <rphifer**At_Symbol_Here**wcenvironmental.com>
Subject: Re: [DCHAS-L] Moving labs in University
Date: Wed, 7 Dec 2016 13:14:29 -0500
Reply-To: rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM
Message-ID: 057701d250b5$c08574c0$41905e40$**At_Symbol_Here**wcenvironmental.com
In-Reply-To


I agree with Ed; the specific regulatory reference is the Materials in Trade Exception (49CFR 173.6). You do not need to hire a “licensed” company to transport hazardous materials from one of your facilities to another, or across campus. You do need to utilize DOT packaging if you are going on public roads, and need a hazardous materials bill of lading (available online or in office supply stores) to accompany the load.

 

This exemption also applies to field studies (stream sampling, for instance) and to Chem Week type chemistry demonstrations at shopping malls and other public places.

 

Hazardous waste transport is not allowed under this exception, but you can transport hazardous waste around your campus as long as you are crossing public roads but not going onto public roads.

 

Russ

Russ Phifer

WC Environmental, LLC

1085C Andrew Drive

West Chester, PA  19380

Fax 800-858-6273

Cell - 610-322-0657

rphifer**At_Symbol_Here**wcenvironmental.com

 

http://www.wcenvironmental.com

 P Please consider your environmental responsibility before printing this e-mail or any other document

 

 

 

 

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Edward Movitz
Sent: Wednesday, December 07, 2016 12:38 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Moving labs in University

 

A government employee, transporting government owned material, from one government location to another government location, either on public roads or not, is not subject to any DOT regulations. 

 

WVU employees can load a WVU truck with WVU chemicals (carefully) and drive to any other WVU campus.

 

DOT regulates transportation in commerce, and the government transportation of government materials as described above is not a commercial activity.

Ed

 

 

 

Edward M. Movitz

Research & Environmental Compliance Officer / FSO

The University of Mississippi 

Laboratory Services

100 Health and Safety Building

P.O. Box 1848

University, MS 38677-1848

U.S.A.

O:+1-662-915-5433 | F: 662-915-5480

movitz**At_Symbol_Here**olemiss.edu |  www.olemiss.edu |  Laboratory Services Web Site

Please Consider the Environment before printing this Email.

Confidentiality Note: The information contained in this e-mail and/or document(s) attached is for the exclusive use of the individual named above and may contain confidential and privileged information. If you are not the intended recipient, please immediately delete this message and all copies of it from your system. You are hereby notified that you are strictly prohibited from reading, photocopying, distributing or otherwise using this e-mail or its contents in any way. If you have received this transmission in error, please notify the sender immediately.

 


From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Barbara Foster <bfoster**At_Symbol_Here**WVU.EDU>
Sent: Wednesday, December 7, 2016 11:10 AM
To:
DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Moving labs in University

 

You don’t mention the specifics on distance and/or routes, but you have to follow all DOT regs when transporting hazardous materials on roadways. You will have to hire a licensed company to move hazardous materials across campus.

 

Barbara L. Foster

College Safety Officer

Eberly College of Arts and Sciences

West Virginia University

DCHAS Fellow - American Chemical Society

304-293-2729 (desk)

304-276-0099 (mobile)

http://safety.eberly.wvu.edu/

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Fu, Zhen
Sent: Wednesday, December 07, 2016 10:01 AM
To:
DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] Moving labs in University

 

Hi all,

 

Could you please share the policy or procedures on moving batch of chemicals within university from one building to the other? What EHS’s role on this matter?

 

Thank you,

 

Zhen

 

--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org

--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org

--- This e-mail is from DCHAS-L, the e-mail list of the ACS Division of Chemical Health and Safety. For more information about the list, contact the Divisional secretary at secretary**At_Symbol_Here**dchas.org

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