1. Hazardous Material Safety Program
Federal Aviation
Administration
University of Michigan Biological Materials workshop
Presented by Richard Hudes October 10, 2017

2. Warning This Presentation Will Not fulfill
Department of Transportation
or International
Hazardous Material / Dangerous Goods Training requirements

3. Valujet Flight 592 May 11, 1996 110 passengers and crew members killed
Oxygen generator

4. Organization

5. Federal Aviation Administration
The Office of Security and Hazardous Materials Safety (AHX)
Mission
Provide quality services to ensure and promote aviation safety in support of national security and the national aerospace system.
Objective
Prevent fatalities resulting from improper shipments of hazardous materials in U.S. air commerce.

6. FAA Hazmat Organization
West
Central
East
Chicago
Re Organization in Progress
One office - One program
Across the Country
Great Lakes
Seattle
New England
New York
Los Angeles
Atlanta
Fort Worth
Headquarters Washington, DC

7. Authority to Inspect & Conduct Investigations
49 United States Code, Section 40113
“The Secretary of Transportation, Under Secretary, or Administrator of the Federal Aviation, may take action as appropriate or necessary to carry out this part, including conducting investigations, prescribing regulations, standards, and procedures, and issuing orders.”

8. Hazmat Overview

9. Hazardous Material Definition
Hazardous material (hazmat) is a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce.

10. 9 Classes of Hazmat 1 Explosives 2 Gases 3 Flammable Liquids
4 Flammable Solids
5 Oxidizer, Organic Peroxide
6 Poison, Infectious Substances
7 Radioactive
8 Corrosive
9 Miscellaneous

11. Hazmat Employer and Employee
A person who employs or uses at least one hazmat employee on a full-time, part time, or temporary basis; and who:
transports hazardous materials in commerce,
causes hazardous materials to be transported in commerce.
Employer
A person who is employed on a full-time, part time, or temporary basis by a hazmat employer and who directly affects hazardous materials transportation safety.
Employee

12. FAA Critical Commodities
Materials that have been identified through quantitative threat assessment to carry an increased probability of catastrophic results when involved in an in-flight incident.

13. FAA Critical Commodities
Oxygen generators/oxidizing gases
Flammable gas torches
Batteries of all types (Lithium!!!)
Gasoline powered devices of all types
Fireworks

14. UPS Dubai September 3, 2010 2 crew members killed
90,000 lithium batteries

15. FAA Critical Commodities
Paint and paint related materials
Regionally selected Critical Commodities are chosen based on trends of non-compliance and/or geographical hotspots.
Infectious substances
Great Lakes Region

16. Hazmat Safety Program (HMSP)
Inspections
Training
Documentation
Packaging
Classification
Trend Analysis
Incidents
Discrepancies
Violations
Risk Analysis
Outreach
Presentations
Advisory Bulletins
Educational Visits
Public Initiatives

17. Hazmat Safety Program
Air Carriers
Accept
Transport
Shippers
Prepare
Offer

18. Controlling Documents
ICAO - International Air
49 CFR - Muti-Modal
Controlling Documents
49 CFR Multi-Modal
ICAO International Air
IATA Optional Air

19. Dry Ice, Biologicals & Non Infectious Specimens – Shipping Perspective
Classification
Training
Packaging
Exceptions /Exemptions
Excepted / De minimis Quantities
Passenger, Crew and Operator Exceptions

20. Dry Ice - Shipping Perspective
Classification
UN 1845 Carbon Dioxide, Solid or Dry Ice, Hazard Class 9 (49 CFR/IATA)
Hazards
Can create an oxygen deficient atmosphere
Releases a large volume of carbon dioxide gas as it sublimates

21. Dry Ice - Shipping Perspective
FAA Advisory Circular AC No :91-76 Hazard Associated with Sublimation of Solid Carbon Dioxide (Dry Ice) Aboard Aircraft

22. Dry Ice - Shipping Perspective
AC 91-76
X = Dry ice loading in lb
(CO2 concentration) (Aircraft Volume, ft3) (Complete air exchanges per hour*)
X =
(sublimation rate)
Example 1a:
Aircraft volume: 5000 ft3
Complete air exchanges per hour: 10
Allowable CO2 concentration (TLV, 0.5%): 0.005
Sublimation rate of 1%/hour (8.5 ft3 CO2/100 lb dry ice/hour): 0.085
(0.005) (5000) (10)
X = = 2941 lbs. of dry ice
(0.085)
Example 1b:
Conditions same as example 1 except that the complete air exchange has doubled.
Complete air exchanges per hour: 20
(0.005) (5000) (20)
X = = 5882 lbs. of dry ice
Example 2: Applies when the shipment consists of small (5 lb) packages of dry ice.
Sublimation rate of 2%/hour ((2 x 8.5 ft3 CO2)/100 lbs. dry ice/hour): 0.17
(0.17)
* Since newer models of airplanes recycle as much as 50% of the cabin ventilated air, instead of providing 100% fresh air as older models did, the number of complete cabin air exchanges of fresh air is required to determine the amounts of dry ice that can be transported. 4

23. Dry Ice - Shipping Perspective
Training
Level of training dependent upon quantity, circumstance, and method of Shipping
49 CFR – Part and Part (training exceptions)
IATA - Must train in accordance with Section 1.5 Training tables to include Packing Instruction 954
49 CFR
Shipping Dry ice in Quantities greater than 2.5 Kg requires hazmat training in accordance with Part
Less than 2.5 Kg Understanding of the packaging instruction
IATA
Full training in accordance with section 1.5

24. Dry Ice - Shipping Perspective
Packaging –
49 CFR/IATA
Venting – the package must be constructed to permit the release of carbon dioxide gas to prevent a build of pressure that could rupture the packaging
Specification packaging not required

25. Dry Ice - Shipping Perspective
Packaging - 49 CFR/IATA
Marked with Proper shipping name Carbon dioxide Solid or DRY ICE and the identification number UN1845
Indication of the net mass of the Carbon dioxide, Solid or Dry Ice must be marked on the outside of the package
Shipments prepared in accordance with IATA must display a Class 9 label

26. Dry Ice - Shipping Perspective
Packaging 49 CFR - Transportation by aircraft
Dry ice is excepted from the shipping paper requirements provided alternative written documentation is supplied containing the following information:
Proper shipping name Dry ice or Carbon dioxide, solid
UN number 1845
Number of packages
The net quantity of dry ice in each package.

27. Dry Ice - Shipping Perspective
49 CFR - Exception 1
Carbon dioxide, solid (dry ice), in quantities not exceeding 2.5 kg (5.5 pounds) per package and used as a refrigerant for the contents of the package is excepted from all other requirements of this subchapter if the package is:
Package Vented
Marked “Carbon dioxide, solid” or “Dry ice”,
Marked with the name of the contents being cooled
Package is marked with the net weight of the dry ice

28. Dry Ice - Shipping Perspective
49 CFR - Exception 2 - Medical Shipments
Carbon dioxide, solid (dry ice), when used to refrigerate materials being shipped for diagnostic or treatment purposes (e.g., frozen medical specimens), is excepted from the shipping paper and certification requirements of this subchapter if:
Package Permits Venting / Operator arrangements
The package is marked “Carbon dioxide, solid” or “Dry ice” and is marked as being transported for diagnostic or treatment purposes.

29. Dry Ice - Shipping Perspective
Exceptions /Exemptions
IATA – Shipper’s Declaration not required (Air Way Bill documentation is)

30. Dry Ice - Shipping Perspective
IATA - Example
Class 9 label
UN 1845, Dry Ice or (Carbon dioxide, solid)
The net weight of dry ice in kilograms
The full name, address, and telephone number of the shipper and consignee
Air waybill requirements

31. Dry Ice - Shipping Perspective
Excepted and De minimis Quantities
Not permitted under
49 CFR / IATA 9

32. Dry Ice - Shipping Perspective
Passenger, Crew and Operator Exceptions
49 CFR / IATA - Dry ice (carbon dioxide, solid), with the approval of the operator:
Quantities may not exceed 2.5 kg (5.5 pounds) per person when used to pack perishables (non Hazardous)
Package must permit the release of carbon dioxide gas
When carried in checked baggage, each package is marked “DRY ICE” or “CARBON DIOXIDE, SOLID,” and marked with the net weight of dry ice or an indication the net weight is 2.5 kg (5.5 pounds) or less

33. Biologicals - Shipping Perspective
Classification
Training
Packaging
Exceptions /Exemptions
Excepted / De minimis Quantities
Passenger, Crew and Operator Exceptions

34. Biologicals - Shipping Perspective
Classification
Shipper Responsibility
Materials classified in accordance with Part 172 and Part 173
Infectious Substance
A material known or reasonably expected to contain a pathogen

35. Biologicals - Shipping Perspective
Category A infectious substances
An infectious substance in a form capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals when exposure to it occurs
Marked label and Shipped as UN2814 or UN2900/Infectious substance, affecting humans or animals /Class 6.2
Specific Instructions - 49 CFR Part or IATA Packing Instruction 620

36. Biologicals - Shipping Perspective
Category B infectious substances
An infectious substance that is not in a form generally capable of causing permanent disability or life-threatening or fatal disease in otherwise healthy humans or animals when exposure occurs.
Must be described as “Biological substance, Category B”, assigned to identification UN3373 and marked with UN 3373 marking
Specific Instructions - 49 CFR Part or IATA Packing Instruction 650
Does not include regulated medical waste - UN 3291.

37. Biologicals - Shipping Perspective
Training
Category A infectious substances
As specified in 49 CFR Part
Specifically and
IATA: Section 1.5 and Packing Instruction 620
Category B infectious substances
Each person who offers or transports a Category B infectious substance under the provisions of this section must know about the requirements of this section.
IATA: Provided clear instruction on Packing Instruction 650
Shipping infectious substances 6.2 Category A requires hazmat training in accordance with Part – Full Training
Shipping infectious substances 6.2 Category B requires hazmat training in accordance with Part – Excepted from full Training
IATA - Requirement similar to 49 CFR

38. Biologicals - Shipping Perspective
Packaging - Category A Infectious Substances
Specification Packaging (Part 178)
Category A infectious substance is a triple packaging consisting of the following components
A leakproof primary receptacle.
A leakproof secondary packaging. Multiple fragile primary receptacles must be either wrapped individually or separated
May contain refrigerants (Dry Ice)

39. Biologicals - Shipping Perspective
Packaging - Category A Infectious Substances
A rigid outer specification packaging
Absorbent material for liquids placed between the primary receptacle and the secondary packaging sufficient to absorb the entire contents
An itemized list of contents
The primary receptacle or secondary packaging must be capable of withstanding, without leakage, an internal pressure producing a pressure differential of not less than 95 kPa (0.95 bar, 14 psi)

40. Category A infectious Packaging Example
Note: The “Technical name” should not be marked on the outer package of a Division 6.2 material

41. Biologicals - Shipping Perspective
Packaging - Category B infectious substances
Similar to Category A infectious substances/Triple Packed
Strong Outer Packaging Vs Specification Packaging
Leak Proof up to 95 kPa
May contain refrigerants (Dry Ice)

42. Biologicals - Shipping Perspective
Category B infectious Packaging Examples

43. Biologicals - Shipping Perspective
Exceptions / Exemptions CFR
Extensive List (just a few)
A material that does not contain an infectious substance or that is unlikely to cause disease in humans or animals
A material containing pathogens that have been neutralized or inactivated and no longer pose a health risk
Dried blood spots or specimens for fecal occult blood detection placed on absorbent filter paper or other material
49 CFR Does not give guidance as to how these shipments are packaged. However the transporters do provide guidance on how they should be prepared
IATA does give guidance (requires triple packaging and marked “Exempt Human Specimen”)

44. Biologicals - Shipping Perspective
Exceptions / Exemptions – Extensive List
49 CFR / IATA
A human or animal sample (including, but not limited to, secreta, excreta, blood and its components, tissue and tissue fluids, and body parts) being transported for routine testing not related to the diagnosis of an infectious disease, such as for drug/alcohol testing, cholesterol testing, blood glucose level testing and prostate specific antibody testing for which there is a low probability the sample is infectious.

45. Biologicals - Shipping Perspective
Exceptions / Exemptions – Packaging and Marking
The packaging must consist of three components – IATA/ICAO requirement
A leakproof primary receptacle(s)
A leakproof secondary packaging; and
An outer packaging of adequate strength for its capacity, mass and intended use
Marked to indicate “Exempt Human Specimen”
Exempt Human Specimen

46. Biologicals - Shipping Perspective
Excepted and De minimis Quantities
Infectious Substances Category A & B not authorized for air transportation
49 CFR / IATA

47. Non-infectious Specimens
Passenger, Crew and Operator Exceptions - 49 CFR / IATA
Applies to Non-infectious specimens in preservative solutions
Such as specimens of mammals, birds, amphibians, reptiles, fish, and insects preserved in small quantities of solution
Quantity Limits - 30 mL of solution per specimen
49 CFR Part 173.4b De minimis Exceptions and Part (a) Passenger and Crew Exceptions
(b) Non-infectious specimens, such as specimens of mammals, birds, amphibians, reptiles, fish, insects and other invertebrates containing small quantities of Ethanol (UN1170), Formaldehyde solution, flammable (UN1198), Alcohols, n.o.s. (UN1987) and Isopropanol (UN1219) are not subject to the requirements of this subchapter provided the following packaging, marking and documentation provisions, as applicable, are met:
(1) The specimens are:
(i) Wrapped in a paper towel or cheesecloth moistened with alcohol or an alcohol solution and placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30 mL; or
(ii) Placed in vials or other rigid containers with no more than 30 mL of alcohol or alcohol solution. The containers are placed in a plastic bag that is heat-sealed;
(2) The bagged specimens are placed in another plastic bag with sufficient absorbent material to absorb the entire liquid contents inside the primary receptacle. The outer plastic bag is then heat-sealed;
(3) The completed bag is placed in a strong outer packaging with sufficient cushioning material that conforms to subpart B of part 173;
(4) The aggregate net quantity of flammable liquid in one outer packaging may not exceed 1 L; and
(5) The outer package must be legibly marked “Scientific research specimens, 49 CFR 173.4b applies.”

48. Non-infectious Specimens
Specific Packaging requirements (triple packed) with cushioning and absorbent material
The completed outer package must be legibly marked “Scientific research specimens, 49 CFR 173.4b applies.” or “Scientific research specimens not restricted Special Provision A180 applies”
49 CFR Part 173.4b De minimis Exceptions and Part (a) Passenger and Crew Exceptions
(b) Non-infectious specimens, such as specimens of mammals, birds, amphibians, reptiles, fish, insects and other invertebrates containing small quantities of Ethanol (UN1170), Formaldehyde solution, flammable (UN1198), Alcohols, n.o.s. (UN1987) and Isopropanol (UN1219) are not subject to the requirements of this subchapter provided the following packaging, marking and documentation provisions, as applicable, are met:
(1) The specimens are:
(i) Wrapped in a paper towel or cheesecloth moistened with alcohol or an alcohol solution and placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30 mL; or
(ii) Placed in vials or other rigid containers with no more than 30 mL of alcohol or alcohol solution. The containers are placed in a plastic bag that is heat-sealed;
(2) The bagged specimens are placed in another plastic bag with sufficient absorbent material to absorb the entire liquid contents inside the primary receptacle. The outer plastic bag is then heat-sealed;
(3) The completed bag is placed in a strong outer packaging with sufficient cushioning material that conforms to subpart B of part 173;
(4) The aggregate net quantity of flammable liquid in one outer packaging may not exceed 1 L; and
(5) The outer package must be legibly marked “Scientific research specimens, 49 CFR 173.4b applies.”

49. Outreach

50. Prohibited Hazmat Commonly Found in Luggage

51. Camping & Outdoors

52. Household Items

53. Miscellaneous

54. FAA Pack Safe
faa.gov/about/initiatives/hazmat_safety/

55. faa.gov/go/hazmatsafety

56. Contact Information
FAA Great Lakes, Regional Operations Center (ROC)
FAA Chicago Regional Hazmat Office
PHMSA Hazardous Materials Information Center (HMIC)
National Response Center (NRC)

57. Questions
Richard Hudes
(513)