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Laboratory Relocation Guidelines

Introduction

This fact sheet provides guidelines for research groups involved in physically relocating laboratories and/or associated research materials from one facility to another, whether on or off campus, and for labs that are shutting down permanently. Several regulations govern transfer and packaging of chemicals and infectious agents, and permits are often required from the CDC to transfer infectious agents. Therefore it is suggested that research groups notify the Department of Environmental Safety (DES) at least 3 weeks prior to moving to new laboratory facilities if assistance is necessary. This fact sheet does not address requirements for relocation of radioactive materials or radiation- producing devices.

Applicable University Policy

It is University of Maryland policy to comply with all federal and State regulations.

Applicable Regulations

• 49 CFR Part 172 -Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response Information, and Training Requirements
• 49 CFR Parts 173, 178, 179 and 180 -Packaging Requirements
• 49 CFR Parts 101, 106 and 107 - Procedures and/or Policies
• 49 CFR Parts 171, 173, 174, 175, 176 and 177 - Operational Rules
• 42 CFR Part 72 - Interstate Shipment of Etiologic Agents - CDC
• International Air Transport Authority - Dangerous Goods Regulations

Summary of Requirements

• Infectious and hazardous substances must be packaged and transported according to various regulations.
• Interstate and intrastate transfer of many infectious agents requires a permit from the CDC, which may take up to 10 working days to obtain.
• Commercial interstate and intrastate transfer (i.e., by commercial carrier, through loading docks, etc.) of hazardous chemical substances and infectious agents requires specific packaging, labeling, manifesting and operational procedures as specified by various Department of Transportation (DOT) regulations.
• Intracampus, interstate or intrastate transport of hazardous chemical substances and infectious agents by University of Maryland employees in University of Maryland vehicles is permitted under DOT regulations, but not recommended due to liabilities assumed by the owner and transporter.
• Commercial transporters of hazardous chemical and infectious substances must receive specific training and maintain a commercial drivers license.

Training

• Training, which can be provided by DES, is required if a commercial carrier will be hired to move infectious substances.
• Training is required for all commercial carriers or receivers of hazardous chemical substances. Training elements include appropriate procedures, packaging requirements, documentation and emergency response.

Reporting

• Accurate manifesting of hazardous chemical substances is required during commercial transport, and must be provided to inspection authorities upon demand.
• Spills, accidents and releases involving hazardous chemicals or infectious substances must be reported to the appropriate agencies.

Inspections

Enforcement of transportation requirements, including inspections, is the responsibility of:

• Federal Highway Administration (motor carriers)
• Federal Railroad Administration (rail carriers)
• Federal Aviation Administration (air carriers)
• Coast Guard (shipments by water)

Recordkeeping

• Training records for commercial transporters of hazardous materials must be maintained.
• Accurate manifests must accompany shipments of hazardous chemical materials at all times when commercially transported or handled.

Intracampus Relocation Guidelines

The Department of Environmental Safety recommends the following minimum procedures be followed when moving chemical substances to other labs on campus:

• Wear personal protective equipment appropriate for the materials being handled (safety glasses, lab coat, gloves, closed-toed shoes, etc.);
• Insure containers are in good condition, properly labeled, without external surface contamination and not likely to leak during transport (Do not move unknown or leaking containers);
• Separate chemicals into compatibility groups and provide separate, labeled boxes for each group. At a minimum, segregate by caustics, acids, flammables (including organic acids), poisons, oxidizers and water reactives;
• Use sturdy, partitioned boxes or pack chemical containers with adequate, compatible padding materials;
• Insure adequate room in box to completely close and seal to permit safe stacking;
• Insure boxes are not overloaded or too heavy to facilitate lifting;
• Insure refrigerated materials are separated into appropriate compatibility groups and packaged with sufficient insulation to maintain desired temperature. If dry ice is used, indicate so on the outer container;
• Transport of hazardous chemicals between laboratories can be arranged by contacting Environmental Safety. There will be a fee associated with this service.

The Department of Environmental Safety recommends the following minimum procedures be followed when moving infectious substances to other labs on campus:

• Sample must be in sealed primary container. Utilize plastic containers whenever possible.
• Place primary container in sealed secondary container, with absorbent between primary and secondary container suitable for the volume transported.
• If dry ice is needed, the secondary container should be placed in an outer container, with the dry ice placed between the secondary and tertiary container (never place dry ice in a sealed container).
• Place biohazard label with agent name, lab address and phone number on outer container.

Written Program

A written compliance program is required for all commercial transporters, shippers or receivers of hazardous chemical substances.

University Resources

Written 5/98
Revised 4/05

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