[Taxacom] Sending museum alcohol specimens to Estonia?

Doug Yanega 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 
collection folks.

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 
shipping policies:

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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