[Taxacom] Sending museum alcohol specimens to Estonia?
dyanega at ucr.edu
Fri Jan 29 18:49:29 CST 2010
>Can someone please help me?
>I need to send 36 skin samples taken from 5 Scorpaeniform fishes to
>Estonia. The skin samples are taken from museum specimens from the
>University of Alberta Zoology Museum alcohol fish collection.
>Each skin sample, was wrapped in cheesecloth, dipped in ethanol to
>moisten the cheesecloth, and then placed in a waterproof screwtop
>vial. Each set of vials from one specimen was then placed in a
>waterproof plastic bag, and then packed in a second waterproof plastic
>bag. All five sets of bags were placed in another waterproof bag and
>then placed in a waterproof styrofoam shipping container. The
>University of Alberta shipper refuses to send the specimens out
>because the box contains "DANGEROUS GOODS", namely ethanol. There is
>less than 1 ml of ethanol in the entire container. Thee is less
>ethanol in the container than there is in a box of chocolates. How do
>Zoology Museums bypass the stupid antiterrorist regulations for
>shipping alcohol preserved specimens?
>Can someone direct me to a specific exemption for museums in the
>shipping regulations for international shipping? Thank you.
There is not a specific exemption (yet - people are working on this),
but there are IATA regulations about "dangerous goods in excepted
quantities" that your shippers need to be aware of. Andrew Bentley at
the KUNHM is probably the #1 authority on this, and here's an excerpt
from one of his most recent messages regarding it:
"It recently came to my attention that the IATA regulations for
Excepted quantities have been revised in the new edition of the IATA
regulations (50th Edition). For those of us who do not have the
~$250 to shell out for the new regulation bible I thought I would
outline the changes and how they affect us natural history wet
NB: Remember, you need to be trained and certified in dangerous
goods handling, packing and shipping in order to use these
regulations to ship dangerous goods in excepted quantities
internationally or domestically. You also need to be registered with
FedEx and UPS in order for them to handle such packages. DHL is no
longer in existence.
The Section of the regulations dealing with Excepted Quantities is
still 2.7 and a pdf of the new regs is attached. Thank you to
Brendan Sullivan at IATA for forwarding the copy and for providing
additional information regarding specific UN numbers."
Rather than forwarding the PDF to the entire taxacom list, I'll send
it to John and offer to pass it along to anyone who needs it (and
requests it via my personal e-mail, not over the list), and encourage
folks to subscribe to the NHCOLL-L mailing list, which is where I
obtained all this info.
One important caveat: I am assuming, for the moment, that Canada also
follows the IATA regulations. If not, for some bizarre reason, then
you will need to find the counterpart regulations for Canada.
That being said, the bottom line for you, right now, is that you need
to get your shippers to read the IATA regs before they argue with
you! However, you would need to have a certified shipper packing your
shipment FOR you; you cannot legally pack and ship alcohol yourself,
nor can anyone in your shipping department do it unless they are
certified. If they ARE certified, and did NOT know the IATA regs,
then one has to wonder how they obtained their certification.
For those who live in the US, it may be worth adding the following
note from Andrew:
"It has just come to my attention that DOT has amended their 49 CFR
173.4 regulations in two major ways that have implications for our
1. They have added section 173.4b "De Minimus Exceptions"
(latest e-CFR attached) which now excludes very small quantities of
hazardous materials (in our case under 1ml of ethanol) from the
regulations. The implications of this are that if you can keep
tissues, for instance, to under 1ml of fluid (and under 100ml total
per package) then there are no dangerous goods requirements for the
package. This has limited application but is something to keep in
2. They have amended 173.4 to now follow IATA labeling criteria
(latest e-CFR attached). You are now required to use the red hatched
label (as per IATA) for DOT (domestic) packages in place of the "This
package conforms to 49 CFR 173.4". However, it appears as if USPS
has yet to adopt these changes (may just be that they are yet to
update their Publication 52). I have emailed my contacts at USPS for
clarification and will let you know as soon as I hear. Until then,
we should continue to use "This package conforms to 49 CFR 173.4".
However, if you are sending packages domestically using FedEx or UPS
then you are required to use the new labeling protocols."
Basically, if you are mailing specimens within the US, and have less
than 1 ml per internal package unit, and less than 100ml total, you
are LEGALLY EXEMPT from the hazmat regs, unless I've badly misread
something. It probably wouldn't hurt to have a label stating "This
package conforms to 49 CFR 173.4b" in case someone ever gets picky;
if they actually know (or look up) what 49 CFR 173.4b *is*, then they
should also know about the exemption!
Doug Yanega Dept. of Entomology Entomology Research Museum
Univ. of California, Riverside, CA 92521-0314 skype: dyanega
phone: (951) 827-4315 (standard disclaimer: opinions are mine, not UCR's)
"There are some enterprises in which a careful disorderliness
is the true method" - Herman Melville, Moby Dick, Chap. 82
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