Hazardous Materials Shipping - FAQ (Frequently Asked Questions)

1. What are hazardous materials?

2. Do I need to take hazardous materials training?

3. I’m only shipping a very small quantity of hazardous materials. Is my shipment still regulated?

4. What training is required to ship hazardous materials?

5. I’m a supervisor at UCB and some of my employees are considered hazardous materials employees. Do I also need training?

6. I’m a supervisor at UCB. My employees are trained and certified to ship hazardous materials. Am I responsible for any record keeping or other special requirements under this policy?

7. What training is provided by EH&S?

8. What’s the difference between a hazardous materials shipper vs. carrier?

9. What are the standard requirements of a hazardous materials shipper?

10. Are all transport companies i.e. airlines, lab couriers, cargo carriers; freight forwarding companies equal to transportation my hazardous materials?

11. How do I know if my material is hazardous for transportation?

12. Can I move hazardous materials around campus?

13. Can I self transport hazardous materials off-campus?

14. If I follow instructions from a web site published by another known university, possibly even a UC campus to prepare or ship hazardous materials, is that acceptable for UCB?

15. If I complete training from a hazardous materials training vendor, is that acceptable to UCB?

16. I’ve completed hazardous materials training from my previous employer; is that acceptable at UCB?

17. How do I ship using dry ice as a refrigerant for non hazardous material?

18. Are batteries considered hazardous materials and regulated for shipping?

19. If I ship a piece of machinery connected to a battery power source during shipment, is that considered a hazardous materials shipment?

20. If I complete hazardous materials training and become certified by UCB, can I ship radioactive materials?

21. Can I return a vendor shipment of hazardous materials if I don’t open it, or if I use the same packaging and markings to return it?

22. Can I ship dry ice in just a Styrofoam container?

23. What considerations do I need to make when shipping a biological substance?

24. I’ve completed vendor training on shipping infectious and biological substances and dry ice. Can I ship chemicals and other hazardous materials with that training and UCB certification?

25. I don’t have time to ship hazardous materials. Can I just self transport it as checked or hand carry luggage?

26. A vendor instructed me to return a hazardous materials shipment via a transport carrier i.e. FedEx using their original packaging and their shipping paper information by attaching another waybill (shipping paper labels)? Is that okay? It’s still there responsibility, right?

27. I need to ship a hazardous material and no one in my department is trained and certified to ship. What do I do?

28. Who is responsible for shipping discrepancies?

29. Can hazardous materials packaging be recycled and reused?

30. I’m shipping empty compressed cylinders previously used to transport hazardous materials, is this considered a hazardous materials shipment?

31. Do I need to do anything special when shipping hazardous materials to an international destination?

32. Does the DOT regulate my shipment if I am originating from and to another country completely outside of the USA?


Frequently Asked Questions and the answers


1. What are hazardous materials?
Hazardous materials are substances or materials that the Secretary of Transportation has determined to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce. Examples of hazardous materials used at UC Berkeley include laboratory reagents, pool chemicals, lubricating oils, paint, batteries, infectious substances, dry ice, and hazardous/radioactive wastes.

2. Do I need to take hazardous materials training?
Faculty, staff and students involved in shipping hazardous materials must be trained to ship or work with someone who has completed hazardous materials shipping training.

Federal and international laws require that anyone who transports, offers advice for transport, or prepares hazardous materials for transport must be trained. Hazardous materials include infectious substances, hazardous chemicals, radioactive materials, dry ice and certain biological substances and genetically modified organisms or micro-organisms. Please see training section.

3. I’m only shipping a very small quantity of hazardous materials. Is my shipment still regulated?
Shipping or transporting even a small quantity of hazardous materials regulated by the Department of Transportation (DOT) or the International Civil Aviation Organization as published in the International Air Transport Association (IATA) still constitutes a hazardous material shipment, although less restrictive shipping requirements may be available. Contact the EH&S Hazardous Materials Shipping Specialist at This email address is being protected from spambots. You need JavaScript enabled to view it. .

4. What training is required to ship hazardous materials?
Hazardous materials employees are required to complete General Awareness and/or Function Specific training depending on the individual’s role in the transportation of hazardous materials. Additionally you are required to complete safety training, which is met by completing your department’s workplace safety training. This required training provides the employee with an understanding of the risks associated with their workplace including the safe handling and safety process for hazardous materials present. You are also required to complete a level of security plan training.

5. I’m a supervisor at UCB and some of my employees are considered hazardous materials employees. Do I also need training?
Yes. As a management representative of UCB, a hazardous materials employer, you are responsible to ensure that your employees who are considered hazardous materials employees complete the appropriate regulatory compliance training. As such, you need to be knowledgeable about the regulations. Check the EH&S web site or call for specific information.

6. I’m a supervisor at UCB. My employees are trained and certified to ship hazardous materials. Am I responsible for any record keeping or other special requirements under this policy?
Departments that ship hazardous materials must establish and maintain files which include copies of all shipping papers and training records. Hazardous materials shipping papers must be retained for at least 24 months after the date of shipment.

Supervisors are required to maintain hazardous materials employees’ training records for three years or for 90 days after employment ends. Supervisors are also required to maintain a list of hazardous materials employees and provide this list to EH&S or government agency personnel upon request.

7. What training is provided by EH&S?
EH&S provides a number of in-house and vendor delivered training to meet general awareness/familiarization, shipping infectious and biological substances, dry ice shipping, general awareness of hazardous materials training (49CFR), shipping hazardous materials by air (IATA), and security awareness. Other training courses are under review for development. Check the EH&S web site or call for specific information.

8. What’s the difference between a hazardous materials shipper vs. carrier?
Carriers and offeror (shipper) responsibilities frequently overlap. However the regulations spell out some very distinct differences from a carrier and an offeror (commonly addressed as the shipper). The shipper of hazardous materials is commonly the owner or the initiator of the shipment. The carrier is the transport company i.e. FedEx. However in some instances the shipper can be one and the same, i.e. FedEx shipping its own hazardous materials, and FedEx transporting/carrying its own shipment.

9. What are the standard requirements of a hazardous materials shipper?
Identification of a hazardous material is the first step, and frequently the most difficult. Of all the shippers (offerors') responsibilities, the requirement to properly classify a hazardous material is very important. It is from the proper identification of the hazardous materials that the other requirements are based on.

HAZARDOUS MATERIALS SHIPPER RESPONSIBILITIES

  • Determine whether material meets the definition of a “hazardous material”
  • Identify the Proper Shipping Name (PSN)
  • Classify using the Hazard Class and or Division Number
  • Determine the Proper Identification Number
  • Apply the appropriate Hazard Warning Label
  • Use compliant packaging
  • Mark the packaging to the regulations
  • Employee Training
  • Emergency Response Information
  • Emergency Response Telephone Number
  • Certification
  • Compatibility
  • Blocking and bracing
  • Placarding
  • Security Plan
  • Incident Reporting


10. Are all transport companies i.e. airlines, lab couriers, cargo carriers; freight forwarding companies equal in the transportation of hazardous materials?
Not all transport companies including airlines are registered to transport hazardous materials. Offering hazardous materials to such a carrier is illegal whether or not the carrier or Transport Company accepts the shipment. Additionally, some carriers and transport companies while registered to transport hazardous materials may do so more restrictively. (i.e., FedEx Ground requires a separate contract to accept hazardous materials for carriage, other hazardous material carriers are prohibited for carriage of hazardous materials by country destination).

11. How do I know if my material is hazardous for transportation?
Only a trained and certified hazardous materials employee may identify and classify material per the regulations. If your shipment is an infectious or biological type shipment, then the Campus BioSafety Officer can classify your material. If your material is chemical, gas, or other miscellaneous material, i.e. magnets, life saving appliances contact EH&S. Remember Radioactive material may only be handled by the EH&S Radiation Safety Team. Contact the EH&S Radiation Safety Team at 642-3073.

12. Can I move hazardous materials around campus?
Carrying and/or transporting hazardous materials entirely on campus roadways does not constitute a shipment or transportation of hazardous materials.

13. Can I self-transport hazardous materials off-campus?
Under certain conditions self transporting hazardous materials off-campus is acceptable. You must request and receive instruction and a written authority from the Hazardous Materials Shipping Specialist.

Note: Transporting hazardous materials via public roadways by campus personnel for use in research or a campus/university related activity while exempt under Federal Regulations, is still considered a regulated shipment under the California Vehicle Code (CVC) or the California Code of Regulations (CCR). However, certain less restrictive regulations may apply. Contact the EH&S Hazardous Materials Shipping Specialist at This email address is being protected from spambots. You need JavaScript enabled to view it. to help determine your options, if any, and your requirements.

14. If I follow instructions from a web site published by another known university, possibly even a UC campus to prepare or ship hazardous materials, is that acceptable for UCB?
No. Only UCB approved training is acceptable unless authorized by the Hazardous Materials Shipping Specialist. While the training content of that other training program might meet the requirements of the HMR, without a review and approval by EH&S, it is not acceptable.

15. If I complete training from a hazardous materials training vendor, is that acceptable to UCB?
Only UCB approved training vendors are acceptable unless authorized by the Hazardous Materials Shipping Specialist. As with question 14, while the training content of the other training program might meet the requirements of the HMR, without a review and approval by EH&S, it is not acceptable.

16. I’ve completed hazardous materials training from my previous employer; is that acceptable at UCB?
While the regulation allows training by a previous employer to meet the regulations, since you will be shipping for UCB, you will need authority from the Hazardous Materials Shipping Specialist to use that training.

17. How do I ship using dry ice as a refrigerant for hazardous material?
Shipping with dry ice is regulated for air and over water shipments. When shipping dry ice with other hazardous material, the dry ice needs to be processed as separate hazardous material. Identification, classification, packaging, marking, labeling and other regulatory requirements including training and certification must be met. See the training section.

18. Are batteries considered hazardous materials and regulated for shipping?
Certain batteries i.e. Lithium, Lead Acid, etc. are regulated for transportation. Please have a certified hazardous materials shipper review your shipment against the regulations.

19. If I ship a piece of machinery connected to a battery power source during shipment, is that considered a hazardous materials shipment?
Shipping a machine or apparatus connected to a battery power source classified as a hazardous material constitutes a hazardous material shipment. However the classification and proper shipping name of the combine unit will most likely change.

20. If I complete hazardous materials training and become certified by UCB, can I ship radioactive materials?
All movement and shipments of radioactive materials on and off campus may only be accomplished by the Radiation Safety Team. Contact EH&S Radiation Safety Team at 642-3073.

21. Can I return a vendor shipment of hazardous materials if I don’t open it, and use the same packaging and markings to return it?
No. The return shipment of a hazardous material is still a hazardous material shipment. If you cause the shipment to be reentered into transportation, you become the formal shipper and now you take on the role of the shipper including all the risks, restrictions and liabilities.

22. Can I ship dry ice in just a Styrofoam container?
No. Styrofoam containers are not acceptable to meet external packaging requirements of a hazardous materials shipment. This applies whether or not a specification package is required. While you may see inbound shipments containing dry ice in just a Styrofoam container. This method of packaging is not compliant.

23. What considerations do I need to make when shipping a biological substance?
Biological and Infectious Substances regulated for transportation include those identified as Infectious Substances-Category A, and Biological Substances-Category B. Exempt Human specimen and Exempt Animal specimen, although exempt per the regulations, require minimum packaging and markings when transported by air.

Infectious Substance (Division 6.2) A material known or reasonably expected to contain a pathogen. A pathogen is a micro- organism (including bacteria, viruses, rickettsiae, parasites, fungi) or other agent, such as a proteinaceous infectious particle (prion) that can cause disease in humans or animals.

Infectious substance (Category A)
An infectious substance in a form capable of causing permanent disability or life threatening or fatal disease in otherwise healthy humans or animals when exposure to it occurs. An exposure occurs when an infectious substance is released outside of its protective packaging, resulting in physical contact with humans or animals.

Classification must be based on the known medical history or symptoms of the source patient or animal, endemic local conditions, or professional judgment concerning the individual circumstances of the source human or animal. Category A poses a higher degree of risk than Category B.

Biological substance (Category B)
An infectious substance not in a form generally capable of causing permanent or life-threatening or fatal disease in otherwise healthy humans or animals when exposure to it occurs. This includes Category B infectious substances transported for diagnostic or investigational purposes.

Note: The Proper Shipping Name (PSN) “Diagnostic Specimens” UN3373 is no longer acceptable by the USDOT and IATA. The new PSN is “Biological Substance, Category B” UN3373.
  • When shipping biological materials that require a Biological Use Authorization (BUA), you must be listed on a current Berkeley campus BUA.
  • Additional permits may be required to ship materials out of state or out of the country. Please contact the Biosafety Officer at This email address is being protected from spambots. You need JavaScript enabled to view it. for additional information.

24. I’ve completed vendor training on shipping infectious and biological substances and dry ice. Can I ship general chemicals and other hazardous materials with that training and UCB certification?
No. The training for shipping infectious and biological substances is function specific training. Shipping general hazardous materials i.e. chemicals require another type of function specific training. . Contact the EH&S Hazardous Materials Shipping Specialist at This email address is being protected from spambots. You need JavaScript enabled to view it.

25. I don’t have time to ship hazardous materials. Can I just self transport it as checked or hand carry luggage?
No. There are regulations that address hand carry and check-in luggage containing hazardous materials. See the section on self transport or checked luggage.

26. A vendor instructed me to return a hazardous materials shipment via a transport carrier i.e. FedEx using their original packaging and their shipping paper information by attaching another waybill (shipping paper labels)? Is that okay? It’s still there responsibility, right?
No it’s not okay. A shipment tendered to a transport carrier by UCB makes UCB the shipper, you and UCB then take on the role of the shipper, including all the risks, responsibilities and liabilities.

27. I need to ship a hazardous material and no one in my department is trained and certified to ship. What do I do?
Contact EH&S for shipping assistance.

28. Who is responsible for shipping discrepancies?
The shipper is ultimately responsible for shipping discrepancies, even when the hazardous materials work is completed by an outside vendor. Fines and penalties assessed by a regulatory agency will be charged back to the shippers department account.

29. Can hazardous materials packaging be recycled and reused?
Yes. Specification packaging for hazardous materials shipments can be recycled and reused provided that the packaging’s structural integrity is intact. Note. You may not reuse any hazardous materials labels from the previous shipment. The packaging must be free of any damage and all prior shipment markings must be removed or obliterated. If you wish to practice the reuse of packaging, please ensure that all hazardous materials information from the prior shipment including dunnage, labels and markings are removed prior to storage.

30. I’m shipping empty compressed cylinders previously used to transport hazardous materials, is this considered a hazardous materials shipment?
Yes. There are special requirements for shipping even empty cylinders with possible hazardous materials residue.

31. Do I need to do anything special when shipping hazardous materials to an international destination?
Shipping hazardous materials from the USA requires meeting not only the hazardous materials regulations, but other regulations as well. Shipments from the University may require a Material Transfer Authority (MTA). Certain biological type shipments may require licensing from various Federal Agencies, i.e. Center for Disease Control (CDC), Department of Fish and Game (DFG), etc. Additionally due the nature of your shipment, you may need to meet export licensing requirements.

International Shipments
Export control regulations have been established for restricting the use of and access to controlled information, goods, and technology for reasons of National security or protection of trade.

In addition to following the guidelines as described above for hazard type classification for the material to be shipped, more information on how to properly ship, transmit, or transfer certain sensitive items, information, or software to foreign persons or entities may be found at the UC Berkeley research web site http://research.chance.berkeley.edu/echome.cfm. Follow the guidelines as described above for hazard type classification for the material to be shipped.

For additional information contact the Director at the Office of the Vice Chancellor for Research ( This email address is being protected from spambots. You need JavaScript enabled to view it. ).

Note: Export from the USA equates to an Import to a foreign country. Check the foreign country’s import prohibitions, restrictions, etc.

If shipping via FedEx, access the FedEx web site and search using the country name along with the term country profile.


32. Does the DOT regulate my shipment if I am originating from and to another country completely outside of the USA?
International Shipments (Originating and terminating shipments completely outside the USA). Shipments completely outside of the USA, without transportation through the U.S. does not require adherence to the US DOT. Check foreign states prohibitions, restrictions, and regulations. Air shipments require compliance to the IATA Dangerous Goods Regulations which meet the International Civil Aviation Organization Technical Instructions.