Advanced Photon Source

A U.S. Department of Energy, Office of Science,
Office of Basic Energy Sciences national synchrotron x-ray research facility

 

16 July 1998
(Revised May 10, 2004)

APS TECHNICAL UPDATE -23

Subject: Transportation of Small Quantities of Hazardous Materials

The ANL Transportation Safety Board has reviewed and approved a proposal that would allow the transportation of small quantities of some hazardous materials, as described in the attached proposal (dated 17 June 1998), by APS users to the APS if transported in full conformance with the DOT Small Quantity Exceptions regulations. A copy of the proposal and the DOT regulation is attached.

Note:

• No exception from ANL policies and procedures for handling radioactive materials is provided.

• Materials must be packaged and labeled in full conformance with DOT regulations.

• Users are encouraged to minimize the transportation of HazMats to and from ANL.

• Users are encouraged, when possible, to use the shipping department resources of their home institution and to use commercial shippers.

• Users are encouraged to avail themselves of ANL-provided shipping, receiving and on-site transportation services.

• Users should be aware that there are additional requirements and restrictions that apply to the movement of HazMat materials by air and other common carriers. These requirements and restrictions are beyond the scope of this exception.

For additional information contact:

Julie Cross - User Technical Interface
jox@aps.anl.gov
Telephone - 630.252.0592

Updated: October 4, 2007

 

distribution:
CAT Safety Coordinators
TB-14 distribution (include in binder section 3)
User Office Staff & Floor Coordinators

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Application of the DOT Small Quantity Exception to
HazMat Transport by APS Users on the ANL Site

(17 June 1998)

The APS Operations Division (AOD) requests that the Argonne National Laboratory (ANL) hazardous material (HazMat) transportation requirements be modified, in compliance with Department of Transportation (DOT) Small Quantity Exceptions (49 CFR 173.4), as follows:

1. That ANL allow, if transported in full conformance with DOT regulations, the entry of small quantities of nonradioactive qualifying materials at any gate. [Refer to Table 1 for qualifying materials and quantity limits.]
2. That ANL allow, if transported in full conformance with DOT regulations, the transport of small quantities of nonradioactive qualifying materials in rental or other user-driven vehicles across the ANL site to the user facilities at the APS.
3. That ANL allow, if prepared for transport in full conformance with the DOT regulations, the off-site transport of nonradioactive qualifying materials without the involvement of ANL personnel.

No exception from the existing ANL standards for handling radioactive materials is being sought. All radioactive materials are to be transported to and from the APS in accordance with ANL requirements (e.g., receipt at Building 46, on-site transfers by ANL Special Materials Handling, off-site shipment by ANL Plant Facilities and Services, etc.).

Materials that are synthesized at ANL and that have unknown hazards, and/or hazards not present in any of the reactants, must be reviewed and the hazards indentified by ANL-trained HazMat personnel prior to transport off the ANL site. Also, for outbound user transport of HazMats, materials with different hazard classification shall be packaged in separate packages (i.e., only one hazard classification per package).

Prior to approval, each experiment proposed for an APS beamline requires user submission of an APS Experiment Safety Assessment Form which includes an identification of the materials that are to be used in the experiment. The APS will require, and verify as part of its Collaborative Access Team (CAT) safety oversight, that CATs, as they carry out their experiment safety responsibilities, verify that the DOT and ANL transportation safety requirements are being met. The APS Experiment Safety Coordinator will coordinate the APS oversight. The APS will deal with noncompliance with the ANL transportation requirements as described in the published APS User Policies and Procedures: "Response to Actions That Are Inconsistent with CAT Safety Plans."

The APS will continue to encourage users to minimize transportation of HazMats to and from ANL. In addition, the APS encourages its users to make appropriate use of institutional and commercial shipping services when shipping materials to ANL and recommends that users avail themselves of ANL-provided shipping, receiving and on-site transportation services. The APS will work with ANL to make standard packaging that meets the DOT requirements (49 CFR 173.4) available to the users.

The APS, with the support of ANL, will coordinate training of the APS CATs on HazMat transportation requirements. The APS will also advise the APS users that there are additional requirements and restrictions that apply to the movement of materials by air and other common carriers. AOD will rely on the ANL Training Management System to record user training and will provide training information upon request.

 

Table 1. Qualifying materials and quantity limits of materials that may be transported to the APS by APS users. This table applies to ground transport only.

* note PG = "packing group"

Note: The revisions to the document reference APS administrative changes and the identity of the ANL Shipping/Receiving building.