The movement of potentially hazardous substances including infectious agents, chemicals, or research animals is both a sensitive subject and one that, depending on the materials being moved and method of movement, can fall under various federal and state regulations. The University of Michigan (U-M) has put into place restrictions on the movement of these materials on university modes of public transportation such as the U-M buses, where individuals unfamiliar with the materials may be potentially exposed or have the perception of exposure. The International Air Transport Association (IATA) Dangerous Goods and US Department of Transportation (DOT) regulate shipment of hazardous substances including infectious substances and chemicals according to the following table:
|INFECTIOUS SUBSTANCE OR HAZARDOUS MATERIAL||DEFINITION|
|Category A||An infectious substance which is transported in a form that, when exposure to it occurs, is capable of causing permanent disability, life-threatening or fatal disease in otherwise healthy humans or animals.|
|Category B||An infectious substance which does not meet the criteria for inclusion in Category A. This can be human, animal, bacterial, viral, or fungal material transported for research, diagnosis, disease, or treatment.|
|Patient/Animal Specimens||Patient and animal specimens for which there is likelihood that pathogens are present.|
|Chemical Preservatives (Dangerous Goods in Excepted Quantities)||Biological specimens containing chemical preservatives such as ethanol, formaldehyde, or formalin.|
|Dry ice||Frozen carbon dioxide that sublimates into gas.|
The following substances are not required to follow the IATA or DOT regulations, but are still subject to U-M restrictions on moving materials around campus:
- Materials that do not contain pathogens or only contains inactivated or neutralized pathogens
- Environmental samples that do not pose a significant threat of infection (i.e, food, water soil, or dust samples)
- Dried blood spots or fecal occult screening tests
- Blood or blood components collected for the purpose of transfusion
- Tissue or organs used for transplantation
- Patient specimens
M-SHIP: Shipping Hazardous Materials at U-M
The M-Ship Shipping Service prepares packages of biological materials, including dry ice, for shipping for U-M research faculty and staff. The shipping consultants at M-Ship will also prepare the appropriate documentation and paper work, including the commercial invoices required for international shipment.
Currently there are two MShip locations one at the NCRC dock and at the dock at BSRB. Researchers may drop off their materials or the shipping consultants can pick up the materials at the lab location.
This service, along with the dry ice, standard packing materials, and labels are of no cost to your department. However, each department is required to pay for the courier shipping fee; and personnel are required to complete the appropriate training courses to better communicate to the consultant the hazards and classification of the biohazardous substance or hazardous material.
Select the appropriate course below based on the material you intend to ship:
- BLS204w – Requirements for Shipping Non-Dangerous Goods with Dry Ice This course fulfills the requirements for: Shipping materials with dry ice with no other hazardous or biological materials included in the shipment.
- BLS209w – Regulations for Shipping Biologics: Infectious Substances Category B This course fulfills the requirements for: Shipping infectious Substances Category B, Dry Ice, certain Chemical Preservatives, Exempt Specimens, and Genetically Modified Organisms (GMO). Note: BLS209w – Category B training fulfills the requirements for most U-M shipments.
NOTE: Each course selected must be documented and completed every two years.
For more information, refer to one of the following resources:
Packaging Requirements for Biological Substances and Hazardous Materials
The Packaging Requirement for Biological Substances and Hazardous Materials document provides information about packaging hazardous substances and materials for shipment. You may print individual topics from this document, which are in the following list:
- Minimum Requirements for Securing Biological Substances and Hazardous Materials
- Classification Guide for Infectious and Biological Substances
- Category A Infectious Substances
- Category B Substances
- Exempt and Unregulated Specimens
- Genetically Modified Micro-Organisms and Genetically Modified Organisms
- Biological Specimen Containing Chemical Preservatives
- Packaging Requirements for Category B, Exempt, Unregulated, and Genetically Modified Substances
- Packaging Requirements for Dry Ice
- Printable Labels
Importation of Biological Materials
Do I Need a CDC Import Permit – https://www.cdc.gov/cpr/ipp/etool.htm
- CDC Importation Regulations Restricted Materials
- Import and Export Requirements for Scientific Specimens
- Organisms and Vectors Protecting America’s Agriculture
- Importing FDA Regulated Products: Biological Products
- U.S. Customs and Border Protection (CBP) Role in Protecting American Agriculture and Public Health
- Concerns Regarding the Importation of Vectors of Human and Animal Disease into the United States
- Importing Biologicals
- FDA Importation of Biologicals
- Import and Export Requirements for Scientific Specimens
- Overview of the Federal Select Agent Program and Import Permit Programs
- CDC Importation Regulations
- Importation of Biological Substances
- Importation of Biological Substances (Part 2)
- Importing Biologics and Vectors: Know Before You Go
Transporting Biological Substances on U-M Campus
Biological substances can be transported (hand-carried or by vehicle) between labs, building floors, and building on the U-M campus. Biological substance include any materials taken from humans or animals, living or dead, fresh or preserved (cells, tissues, organs, blood and body fluids), cultures, suspensions or lyophilized prokaryotic or eukaryotic microorganisms, viruses, sub-viral particles, recombinant products, or parasites used for teaching or research purposes.
Biological substances must be placed in three different packages when being transported, by hand-carry or vehicle, to a new location. The following table describes each type of packaging:
|A leak proof primary receptacle||Primary receptacles must be able to be secured with a lid or sealed with a screw top lid or with tape or parafilm. NOTE: Liquid samples must be surrounded by absorbent material (absorbent towels) to contain the total volume of the liquids and absorb any shock during transport.|
|Leak proof secondary packaging||The secondary package must be sealed so that it will not open and spill the contents during transport.|
|Outer Container||The outer container must be adequate in strength and have a secure lid.|
Use the following precautions when hand-carrying biological substances on the U-M campus:
- When possible, use a cart to move the biological substances
- Take care when moving materials through public spaces or high traffic walkways
- Do not wear laboratory gloves in public access areas
- Carry a spill kit of gloves, lab coat, eye wear, disinfectant, and absorbent material during transport to clean up any spills that may occur
NOTE: Contact EHS at (734) 647-1143 if assistance is needed to clean up a spill.
Transporting Biological Substances in a Vehicle
U-M recommends using the following transportation services to transport biological material on U-M campus:
- The Bio Research Shuttle
- Commercial or private carriers (i.e., commercial transport companies). NOTE: Commercial transport companies are subject to the Hazardous Materials Regulations. These include companies such as UPS, FedEx, as well as medical couriers Metro Delivery, Unity Lab Services, etc.
- Personal vehicle – WARNING: U-M does not recommend transporting biological substances in personal vehicles. If this option is used, the driver must be notified that biological substances are in the container and must be informed of the requirements in this section.
Accidents during movement or transportation of any of these materials can potentially result in serious harm to persons and property. Release and spills of these materials may involve police and EHS Hazardous Materials Management responders including clean-up and cost of recovery.
Training for Shippers of Biological Materials to Off-site Locations
Personnel who prepare biological materials for shipment, or will transport or receive biological material shipments, must be trained and certified by EHS. In addition, they must maintain a copy of the training certificate (you can print a copy of your training certificate from My LINC). The following courses are required, as appropriate, for each person engaged in shipping hazardous materials. These courses must be taken every two years.
|COURSE NUMBER||PERSONNEL WILL BE QUALIFIED TO:|
|BLS204W||Handle, package, and ship materials refrigerated with dry ice. NOTE: This course is intended for those shipping non-regulated materials but using dry ice.|
|BLS209W||Prepare and ship packages containing exempt specimens, genetically modified organisms (GMOs), and category B substances. Information on shipping these materials with dry ice and chemical preservatives is also included in this training.|
Shipping with Dry Ice
Dry ice is classified by DOT and IATA as a “miscellaneous” hazard, Class 9. Dry ice is considered hazardous during transportation for the following reasons:
- Explosion hazard: dry ice releases a large volume of carbon dioxide gas as it sublimates. If packaged in a container that does not allow for release of the gas, it may explode, causing personal injury or property damage.
- Suffocation hazard: a large volume of carbon dioxide gas emitted in a confined space may displace oxygen and create an oxygen deficient environment.
- Contact hazard: dry ice is a cryogenic material that causes severe frostbite upon contact with skin.
For information about packing dry ice, in which no other biological substances will be packaged, refer to the document Packaging Requirements for Dry Ice.
For information about packing biological substances with dry ice, refer to the document Packaging Requirements for Biological Substances and Hazardous Materials.
If you ship biologics frequently, it may be cost-effective for you to order your supplies from vendors that sell UN certified biological shipping systems.
If you ship biologics occasionally or on a limited basis, it may be cost-effective for you to get your shipping system supplies from EHS at cost. All you need to do is complete the UN Certified Biological Shipping Systems Available form. NOTE: You must complete the appropriate shipping biological material training course before you ship.